Minnesota's PFAS Blueprint

February 2021

Minnesota’s PFAS Blueprint

A plan to protect our communities and our environment from

per- and polyfluorinated alkyl substances

PFAS planning document

Minnesota Pollution Control Agency

520 Lafayette Road North | Saint Paul, MN 55155-4194 |

651-296-6300 | 800-657-3864 | Or use your preferred relay service. | [email protected]

This report is available in alternative formats upon request, and online at www.pca.state.mn.us.

Document number: p-gen1-22

This document was written by a large number of staff and managers from the MPCA, MDH, DNR and

MDA. The initial drafts of issue papers were written by PFAS Lateral Team subject experts. Primary

coordination, compilation, and editing was done by Sophie Greene, MPCA’s PFAS coordinator.

Drafts of issue papers were reviewed by the relevant program management, the entire Staff PFAS

Lateral Team, and the entire Manager PFAS Lateral Team. Finally, the document was reviewed by

commissioners of participating agencies.

Authors

Sophie Greene

Catherine Neuschler

Contributors/acknowledgements

Mark Rys (MPCA)

Yodit Sheido (MPCA)

Summer Streets (MPCA)

Katherine Sullivan (MPCA)

Randy Thorson (MPCA)

Kayla Walsh (MPCA)

Virginia Yingling (MDH)

Rajinder Mann (MDA)

Kristie Ellickson (MPCA)

Angela Preimesberger

(MPCA)

Barbara Keller (DNR)

Bruce Monson (MPCA)

Phil Monson (MPCA)

Michelle Carstensen (DNR)

Patricia Mccann (MDH)

Melissa Peck (MPCA)

Kathleen Hall (MDA)

Deanna Scher (MDH)

Timothy Farnan (MPCA)

Sarah Yost (MPCA)

Will Backe (MDH)

Betsy Edhlund (MDH)

Gary Krueger (MPCA)

Alycia Overbo (MDH)

Tannie Eshenaur (MDH)

Ling Shen (DNR)

Tom Burri (DNR)

Paul Radomski (DNR)

Josh Burman (MPCA)

John Gilkeson (MPCA)

Nicole Neeser (MDA)

Justin Barrick (MPCA)

Anthony Bello (MPCA)

Sheryl Bock (MPCA)

Andri Dahlmeier (MPCA)

Jane de Lambert (MDH)

Mark Elliott (MPCA)

David Fairbairn (MPCA)

Helen Goeden (MDH)

Rebecca Higgins (MPCA)

Alister Innes (MPCA)

James Jacobus (MDH)

Todd Johnson (MDH)

Scott Knowles (MPCA)

Dorian Kvale (MPCA)

Jaramie Logelin (MPCA)

Laura Marti (MPCA)

Catherine O’Dell (MPCA)

Editing and graphic design

Paul Andre

Amanda Scheid

Elizabeth Tegdesch

 
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Contents 
Executive summary ....................................................................................................................................... 1 
Introduction .................................................................................................................................................. 3 
Background ............................................................................................................................................... 4 
Addressing and managing PFAS .............................................................................................................. 10 
PFAS summary and needs ....................................................................................................................... 13 
Preventing PFAS pollution........................................................................................................................... 14 
Background ............................................................................................................................................. 16 
Past and ongoing efforts ......................................................................................................................... 19 
Gaps and opportunities .......................................................................................................................... 21 
Overview of intersectional issues ........................................................................................................... 26 
Measuring PFAS effectively and consistent ................................................................................................ 27 
Background ............................................................................................................................................. 29 
Past and ongoing efforts ......................................................................................................................... 33 
Gaps and opportunities .......................................................................................................................... 38 
Overview of intersectional issues ........................................................................................................... 41 
Quantifying PFAS risks to human health ..................................................................................................... 42 
Background ............................................................................................................................................. 44 
Past and ongoing efforts ......................................................................................................................... 47 
Gaps and opportunities .......................................................................................................................... 50 
Overview of intersectional issues ........................................................................................................... 54 
Limiting PFAS exposure from drinking ........................................................................................................ 56 
Background ............................................................................................................................................. 58 
Past and ongoing efforts ......................................................................................................................... 63 
Gaps and opportunities .......................................................................................................................... 69 
Overview of intersectional issues ........................................................................................................... 74 
Reducing PFAS exposure from consuming fish and game .......................................................................... 75 
Background ............................................................................................................................................. 77 
Past and ongoing efforts ......................................................................................................................... 79 
Gaps and opportunities .......................................................................................................................... 83 
Overview of intersectional issues ........................................................................................................... 86 
Limiting PFAS exposure from food .............................................................................................................. 87 
Background ............................................................................................................................................. 89 
Past and ongoing efforts ......................................................................................................................... 93 

 
ii 
Gaps and opportunities .......................................................................................................................... 96 
Overview of intersectional issues ......................................................................................................... 100 
Understanding risks from PFAS air emissions ........................................................................................... 101 
Background ........................................................................................................................................... 103 
Past and ongoing efforts ....................................................................................................................... 106 
Gaps and opportunities ........................................................................................................................ 108 
Overview of intersectional issues ......................................................................................................... 112 
Protecting ecosystem health .................................................................................................................... 113 
Background ........................................................................................................................................... 115 
Past and ongoing efforts ....................................................................................................................... 118 
Gaps and opportunities ........................................................................................................................ 121 
Overview of intersectional issues ......................................................................................................... 125 
Remediating PFAS contaminated sites ..................................................................................................... 126 
Background ........................................................................................................................................... 128 
Past and ongoing efforts ....................................................................................................................... 131 
Gaps and opportunities ........................................................................................................................ 141 
Overview of intersectional issues ......................................................................................................... 145 
Managing PFAS in waste ........................................................................................................................... 147 
Background ........................................................................................................................................... 149 
Past and ongoing efforts ....................................................................................................................... 155 
Gaps and opportunities ........................................................................................................................ 164 
Overview of intersectional issues ......................................................................................................... 172 
Appendix A. List of gap-filling opportunities identified in all issue papers ............................................... 173 
Table A-1. All gap-filling initiatives described in issue papers. ............................................................. 173 
Table A-2. Gap-filling initiatives organized by timeframe. ................................................................... 178 
Appendix B. List of Minnesota PFAS values and selected other PFAS risk values .................................... 180 
Appendix C. Relevant federal actions ....................................................................................................... 183 
 
   

iii

Figures

Figure 1. Summary of PFAS families, retrieved from ITRC ............................................................................ 4

Figure 2. Schematic diagram of PFAS risk assessment and method availability ........................................ 47

Figure 3. How PFAS guidance has been revised to reflect new findings in the toxicological literature ..... 48

Figure 4. Categories of public water systems ............................................................................................. 58

Figure 5. State agency roles in groundwater monitoring ........................................................................... 59

Figure 6. Process of progressive risk reduction as sites move through the Superfund process .............. 129

Figure 7. Map of Project 1007 Corridor .................................................................................................... 134

Figure 8. Summary of industrial sources of PFOS to Municipal WWTPs (Michigan) ................................ 152

Figure 9. PFAS levels in leachate from construction and demolition landfills, municipal solid waste

landfill, and municipal solid waste ash landfills in Florida. ....................................................................... 152

Figure 10. Schematic diagram of how PFAS could cycle through waste facilities and environmental

media. ....................................................................................................................................................... 153

Figure 11. PFAS levels in down-gradient groundwater wells at CLP sites ................................................ 160

Tables

Table 1. PFAS naming system, retrieved from ITRC. ..................................................................................... 5

Table 2. A non-exhaustive list of PFAS past or ongoing uses in various industries. ..................................... 6

Table 3. Summary of community water system monitoring efforts from 2006 to 2025. .......................... 61

Table 4. PFOS fish consumption advisory levels. ........................................................................................ 80

Acronyms

5:3 FTCA

5:3 Fluorotelomer carboxylic acid

AFFF

Aqueous film-forming foams

ARARs

Applicable or relevant and appropriate requirements

ARAM

Alternative Risk Assessment Methodology

ATP

Aquatic Toxicity Profile

C&D

Construction and demolition

CAA

Clean Air Act

CAPs

Criteria Air Pollutants

CDC

Centers for Disease Control and Prevention

CEC

Contaminant of emerging concern

CEH

Center for Environmental Health

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CLP

Closed Landfill Program

CWA

Clean Water Act

CWS

Community water system

DNR

Department of Natural Resources

DoD

Department of Defense

DWRF

Drinking Water Revolving Fund

ECCC

Environment and Climate Change Canada

ECOTOX

ECOTOXicology knowledgebase

EFSA

European Food Safety Authority

EPA

US Environmental Protection Agency

Fluorine-free firefighting foam

FCMP

Fish Contaminant Monitoring Program

FDA

Food and Drug Administration

FOSA

Perfluorooctane sulfonamide

FTOH

Fluorotelomer alcohol

GAC

Granular activated carbon

HAP

Hazardous air pollutant

HBV

Health Based Value

HHRAP

Human Health Risk Assessment Protocol

HRL

Health Risk Limit

ITRC

Interstate Technology and Regulatory Council

LCCMR

Legislative-Citizen Commission on Minnesota Resources

LSTS

Large Subsurface Treatment Systems

MACT

Maximum achievable control technology

MCL

Maximum contaminant level

MDA

Minnesota Department of Agriculture

MDH

Minnesota Department of Health

MERLA

Minnesota Environmental Response and Liability Act

MNELAP

Minnesota Department of Health Environmental Laboratory Accreditation Program

MPCA

Minnesota Pollution Control Agency

MPG

Multi-purpose Grant

MSW

Municipal solid waste

NAM

New approach methodology

NPDES

National Pollutant Discharge Elimination System

ORD

Office of Research and Development (EPA)

Pollution Prevention

PBT

Persistent, bioaccumulative and toxic

PCB

Polychlorinated biphenyl

PFAS

Per- and polyfluoroalkyl substances

PFBA

Perfluorobutanoic acid

PFBS

Perfluorobutane sulfonate

PFC

Perfluorochemical

PFCA

Perfluorinated carboxylic acid

PFDA

Perfluorodecanoic acid

PFDoDA

Perfluorododecanoic acid

PFDS

Perfluorodecane sulfonic acid

PFHpA

Perfluoroheptanoic acid

PFHpS

Perfluoroheptane sulfonic acid

PFHxA

Perfluorohexanoic acid

PFHxS

Perfluorohexane sulfonate

PFNA

Perfluorononanoic acid

PFOA

Perfluorooctanoic acid

PFOS

Perfluorooctane sulfonate

PFPeA

Perfluoropentanoic acid

PFSA

Perfluorinated sulfonic acid

PFTeDA

Perfluorotetradecanoic acid

PFTrDA

Perfluorotridecanoic acid

PFUnDA

Perfluoroundecanoic acid

PHL

Public Health Lab

PIGE

Particle induced gamma emission

RCRA

Resource Conservation and Recovery Act

REACH

Registration, Evaluation, Authorization and Restriction of Chemicals

RMAD

Resource Management and Assistance Division

SDS

State Disposal System

SSOM

Source-separate organic material

TOF

Total organic fluorine

TOP

Total oxidizable precursor

TRI

Toxics Release Inventory

TSCA

Toxic Substances Control Act

UCMP

Unregulated Contaminant Monitoring Project

UCMR

Unregulated Contaminant Monitoring Rule

USDA

United States Department of Agriculture

USGS

United States Geological Survey

vPvB

Very persistent and very bioaccumulative

WIC

Women, Infants, and Children

WQC

Water Quality Criteria (site-specific)

WQS

Water Quality Standards

WWTP

Wastewater treatment plant

Minnesota’s PFAS Blueprint • February 2021

Executive summary

Per- and polyfluoroalkyl substances (PFAS) are a large family of chemicals that are ubiquitous in the

environment due to use across economic sectors since the 1930s. Substances in the PFAS family are

either persistent in the environment or transform to different PFAS that are persistent. Some PFAS

bioaccumulate in living organisms. At certain levels they are toxic, causing adverse health effects in

humans, fish, and wildlife.

Over the last 20 years, PFAS have been considered important emerging contaminants. Actions have

been taken around the world to study them. Minnesota was one of the first states to identify PFAS

pollution and has been a leader in studying the impacts of PFAS and responding to PFAS contamination.

Once considered “contaminants of emerging concern,” PFAS have now truly “emerged” as worrisome

contaminants in the regulatory and scientific communities. Hundreds of thousands of reports on PFAS

environmental occurrence, human toxicity, and animal toxicity have been published.

Across the United

States, federal and state health and environmental regulators are taking steps to incorporate PFAS into

their programs.

PFAS are present in the environment and will remain so for a long time. Significant actions are needed to

prevent adverse effects of PFAS by interrupting the pathways that result in people and organisms being

exposed. While management and mitigation actions have significant positive effects, ultimately we

cannot clean up our way out of the PFAS problem. Instead, the pollution must be prevented from the

outset through restrictions or bans on PFAS uses, assistance and financial support for reformulation, and

regulation of PFAS releases to the environment.

This document provides an overview of PFAS, followed by an in depth discussion of PFAS in 10 key issue

areas. Each issue paper describes the many PFAS initiatives taken and underway in Minnesota and

identifies key areas of opportunity moving forward on managing and addressing PFAS. The papers also

highlight the significant interconnections between different areas, illustrating the complexity and

difficulty of managing PFAS. The issue papers cover a broad range of topics. Across all those topics,

themes emerge among the needed actions.

Pollution prevention: The persistency of PFAS mean that they do not break down in the

environment. Treatment and destruction of PFAS is expensive and not always feasible or complete.

Effort is needed to limit non-essential PFAS uses and find alternatives to PFAS when uses are

currently needed.

Investigation of PFAS discharges: To prevent PFAS pollution, we need to understand the wide range

of places where PFAS has been or are currently used and how these uses result in PFAS releases to

the environment.

Environmental monitoring: More detailed information about which PFAS are in the environment

and at what levels is needed. This may require use of non-traditional analytical methods like non-

targeted analysis. Non-targeted analysis allows for the detection of hundreds of PFAS in a sample,

without requiring the availability of traditional analytical methods.

Toxicity research: Additional research is needed to understand the toxicity of PFAS to people and

environmental organisms. Without this research, it can be impossible to develop risk-based values

for a given PFAS.

Dimensions. (2020, December 9) PFAS keyword search. Retrieved from:

https://app.dimensions.ai/discover/publication?search_mode=content&search_text=PFAS&search_type=kws&search_field=full

_search

Similarly persistent and bioaccumulative toxics such as polychlorinated biphenyls (PCBs) and dichlorodiphenyltrichloroethane

(DDT) were banned as their impacts became clear.

Minnesota’s PFAS Blueprint • February 2021

Regulatory development: PFAS are generally not yet well incorporated into environmental

regulatory programs. Program development needs to consider necessary and appropriate changes

to incorporate PFAS monitoring, limits, or best management practices into facility permits.

The issue papers are intended to provide a shared grounding on key topics related to PFAS and to direct

the conversation to areas of focus for future needs. Some of the opportunities would represent an

expansion of existing efforts to manage PFAS; some would require additional resources and structures

to build them into comprehensive and holistic PFAS programs. Choosing to pursue some of these future

opportunities would involve program development, detailed discussions with potential partners,

stakeholder engagement, and collaboration across impacted Minnesotans.

This blueprint identifies (in Appendix A), actions that could be taken over the short-term and those that

would take longer to complete based on current resources and priorities. Combined with items being

advanced in the current legislative session, the “short-term” initiatives include opportunities to reduce

and prevent PFAS pollution, advance key areas of PFAS research, begin to incorporate PFAS into

regulatory programs, and improve the efficiency of clean-ups at PFAS-contaminated sites.

The future needs and opportunities related to PFAS are extensive, and the state agencies and our partners

in Minnesota, other states, and the federal government will need to work together to advance projects

strategically towards the collective goal to protecting human health and the environment from the impacts

of PFAS. The medium/long-term opportunities identified in this report represent a broad range of

activities, some of which are connected and dependent on each other. The state of science and regulation

of PFAS is dynamic; research and policy are being advanced by state agencies, federal agencies, academics,

and corporations. The ongoing work of others will almost certainly fill some of the gaps identified in this

report, and will influence the work that needs to be done in Minnesota. Minnesota expects to revisit this

plan over time to adjust to the changing scientific and regulatory landscape.

2021 legislative proposals

Conduct additional investigations of PFAS groundwater plumes down-gradient of closed landfills

Conduct routine PFAS monitoring in fish

Engage with WWTPs to identify industrial PFAS sources and opportunities for pretreatment

Establish authority for MPCA to request data regarding contaminants of potential environmental

concern

Conduct study of biosolids fate and transport following land-application

Formally define PFAS as hazardous substances under MERLA

Accelerate existing PFAS Pilot Inventory

Short-term actions

Compile information on inhalation PFAS toxicity

Issue guidance on the collection and disposal of PFAS-containing firefighting foam concentrate and

wastewater

Research cutting-edge risk assessment techniques for data-poor PFAS

Update guidance for recommended analyte sampling at clean-up sites to include PFAS

Develop statewide water quality standards for PFAS - Class 1 drinking water

Develop a plan for monitoring PFAS in groundwater at active landfills

Develop a plan for monitoring PFAS at NPDES permitted facilities

Develop a plan for performance testing for PFAS at permitted air sources

Minnesota’s PFAS Blueprint • February 2021

Introduction

Per- and polyfluoroalkyl substances (PFAS), previously called perfluorochemicals or PFCs, are a large

family of chemicals that are widely present in the environment. When a new or unexpected pollutant is

found in the environment, that discovery can lead to a wide range of actions like monitoring to

determine where the pollutant is found, investigation to determine how the pollutant is getting into the

environment, and research to identify potential adverse impacts the pollutant might have on human or

wildlife health. When a pollutant is suspected to be in the environment and a cause for concern, it is

often called a “contaminant of emerging concern.” As the impacts of a pollutant become more clear,

federal and state environmental agencies may take steps to reduce or regulate levels of the pollutant.

Once regulated, pollutants are no longer considered an “emerging concern” and are instead included in

the routine regulatory processes managed by state and federal governments.

Over the last 20 years, PFAS have been considered important “contaminants of emerging concern” and

actions have been taken around the world to study them. Minnesota was one of the first states to

identify PFAS pollution and has been a leader in studying their health effects and in responding to

contamination. At this point, in 2021, PFAS have truly “emerged” in the regulatory and scientific

landscape as contaminants of concern. Although they are not fully regulated, it is clear that PFAS are

ubiquitous in the environment and, at certain levels, have adverse effects on both human and wildlife

health. Across the United States, federal and state health and environmental regulators are taking steps

that are moving PFAS from the space of being “emerging contaminants” to ones that are regularly

managed and incorporated into our health and environmental programs. Navigating this transition is

complex.

Minnesota’s state agencies have already undertaken significant efforts to address PFAS. However, the

incorporation of PFAS into regulatory work and research has occurred generally in response to specific

events and as resources arise. While good work has been done, more is needed.

Working together, the Minnesota state agencies plan to take a holistic and systematic approach to

addressing PFAS. To that end, the Minnesota Pollution Control Agency (MPCA) has established a PFAS

Coordinator position and designed an interagency lateral team to manage PFAS issues in a way that is

efficient and prevents unintended consequences. This blueprint is the first major work product from the

PFAS Coordinator and lateral team. It presents an overview of PFAS generally, followed by a discussion

of PFAS concerns in 10 key issue areas. Each issue paper describes the many PFAS initiatives taken in

Minnesota relevant to that topic and those currently underway. The issue papers then identify areas of

opportunity for moving forward on managing and addressing PFAS and highlight the significant

interconnections or overlaps between different topic areas, illustrating the complexity and difficulty of

managing PFAS through regular regulatory mechanisms.

The 10 issue areas are:

1. Preventing PFAS pollution

6. Limiting PFAS exposure from food

2. Measuring PFAS effectively and consistently

7. Understanding risks from PFAS air emissions

3. Quantifying PFAS risks to human health

8. Protecting ecosystem health

4. Limiting PFAS exposure from drinking water

9. Remediating PFAS contaminated sites

5. Reducing PFAS exposure from consuming fish

and game

10. Managing PFAS in waste

Minnesota’s PFAS Blueprint • February 2021

The papers are intended to provide a shared grounding in past work on issues related to PFAS, and to

direct the conversation to key areas of focus for future needs in managing PFAS to protect human health

and the environment. The identified future opportunities are not directives or fully realized program

proposals. In many cases, additional resources and structures (and in some cases additional authorities)

would be needed to allow the agencies to build projects under consideration into comprehensive and

holistic PFAS programs. The issue papers are meant to open space for discussion on how to move

forward with managing PFAS in each area. Choosing to pursue many of the future opportunities would

involve stakeholder engagement, discussion, and collaboration across impacted Minnesotans.

Background

What are PFAS?

PFAS are a large group of manmade chemicals containing at least one fully fluorinated carbon in a chain

attached a “functional group” that has specific characteristics.

Invented in the 1930s, PFAS have been

used in multiple applications across many industries for uses including repelling water and grease,

reducing friction, reducing fire

risk, and acting as an

insulator, especially under

conditions where materials

are needed that are non-

reactive and heat-resistant.

PFAS are desirable in

commercial and industrial

applications because of

their durability, but that

durability also means that

they do not readily break

down over time in

environmental conditions.

In addition, they are not

easily removed through conventional pollution treatment at facilities like wastewater treatment plants

(WWTP). The persistence of PFAS in the environment has led to the nickname of “forever chemicals.”

PFAS are unlike other classes of environmental contaminants in terms of the number of unique

structures in the group, their persistence in the environment, and their widespread societal use.

It is difficult to identify all PFAS with specificity. There are currently over 5,000 PFAS structures included

in the US Environmental Protection Agency’s (EPA) master list of structurally defined PFAS, and over

9,000 identified PFAS chemistries.

New PFAS are being invented, used in industry, incorporated into

commercial products, and released to the environment every day. A key challenge in understanding and

regulating PFAS is the currently limited but ever-expanding knowledge about their use, their presence in

the environment, the resulting health and environmental effects, and how these characteristics may

differ based on the specific type of PFAS. Figure 1 provides a basic summary of the different subfamilies

of PFAS. PFAS are sometimes discussed as being “long-chain” or “short-chain,” depending on the

Interstate Technology Regulatory Council (ITRC). (2020, April). Naming Conventions and Physical and Chemical Properties of

Per- and Polyfluoroalkyl Substances.

https://pfas-1.itrcweb.org/fact_sheets_page/PFAS_Fact_Sheet_Naming_Conventions_April2020.pdf

EPA, National Center for Computational Toxicology. (2020, September 16). PFAS Master List of PFAS (Version 2).

https://comptox.epa.gov/dashboard/chemical_lists/PFASMASTER

Figure 1. Summary of PFAS families, retrieved from ITRC.

Minnesota’s PFAS Blueprint • February 2021

number of fluorinated carbons in the chain; the more carbons, the longer the chain. The precise

definition of “long-chain” depends on the exact PFAS and their functional groups, but in general “long-

chain” refers to perfluorinated carboxylic acids (PFCAs) with eight or more carbons (seven or more

carbons are perfluorinated) or perfluorinated sulfonic acids (PFSAs) with six or more carbons (six or

more carbons are perfluorinated). Short-chain refers to PFCAs with seven or fewer carbons (six or fewer

carbons are perfluorinated) and PFSAs with five or fewer carbons (five or fewer carbons are

perfluorinated).

Table 1, below, provides some basics on PFAS naming conventions.

Table 1. PFAS naming system, retrieved from ITRC.

ITRC. (2020). PFAS Chemistry, Terminology, and Acronyms. Retrieved from: https://pfas-1.itrcweb.org/2-2-chemistry-

terminology-and-acronyms/. Note that this is definition is a simplification that does not consider replacement chemistries with

non-carbon substitutions to the backbone of the chemical.

Minnesota’s PFAS Blueprint • February 2021

To date, work on PFAS has focused on two of the most studied PFAS, perfluorooctane sulfonate (PFOS)

and perfluorooctanoic acid (PFOA). The major manufacturers of PFAS in the United States agreed to

phase out the use of PFOS and PFOA in 2006, but production of PFOA and PFOS continued through 2010

and regulations still allow PFOS and PFOA to be incorporated in some products manufactured elsewhere

but sold in the United States.

Where are PFAS used?

PFAS are used in a wide variety of industrial process and commercial products. PFOS and PFOA were

once manufactured by 3M in Minnesota. PFOS was a key ingredient in the stain repellant Scotchgard

and was used in surface coatings for common household items such as carpets, furniture, and

waterproof clothing. PFOS was also included in fire-fighting foams used at airports, fuel refineries, and

other facilities. PFOA was used in the production of many products, included (but not limited to)

nonstick coatings for cookware, coatings for carpets, coatings for upholstery, coatings for clothing, floor

wax, sealants, and even some dental flosses. Products containing PFOA and PFOS produced before the

“phase out” are still in circulation in homes and businesses around Minnesota. These products are

currently in use or making their way into landfills, compost facilities, and WWTPs around the state.

Other PFAS that transform to PFOA or PFOS are still being imported. For these reasons, though PFOA

and PFOS are considered “legacy” PFAS and are no longer being manufactured locally, new contributions

of PFOA and PFOS to the environment continue. Other PFAS are regularly manufactured and used in a

variety of industries and products ranging from cross country ski wax to car wax, medical devices,

textiles, and many more. A non-exhaustive list of industries known to use PFAS and the corresponding

applications are included in Table 2.

Table 2. A non-exhaustive list of PFAS past or ongoing uses in various industries.

Industry branch

Examples of uses

Aerospace

Brake and hydraulic fluids, wire and cable, thermal control and radiator surfaces

Air conditioning

Working fluid

Ammunition

Reduces likelihood of unplanned explosion due to shock, prevents degradation of

polymer coatings

Apparel

Breathable membranes, water-resistant finish

Automotive

Automotive waxes (resistant), windshield wiper fluid (prevents icing), heat

transfer fluid, stain-resistant coatings on carpets and seats, glass, and some

engine parts

Biotechnology

Cell cultivation, filtration and microporous membranes

Building and construction

Architectural membranes (e.g. roofs), cement additive, cable and wire insulation

Chemical industry

Production of chlorine and caustic soda, processing aids, extrusion films, solvents,

inert reaction media

Cleaners

Wetting agent, stabilizes dry cleaning fluids

Coatings, paints and

varnishes

Emulsifier in paint, anti-stick coatings, coatings for food contact materials

Cookware

Prevent sticking to the pan

Electronics

Heat transfer fluids, etching solution, cleaning solvent, dielectric fluids

EPA, Office of Chemical Safety and Pollution Prevention. (2020, February 20). EPA Continues to Act on PFAS, Proposes to Close

Import Loophole and Protect American Consumers. [Press release]. Retrieved from: https://www.epa.gov/newsreleases/epa-

continues-act-pfas-proposes-close-import-loophole-and-protect-american-consumers

Adapted from Glüge, J., Scheringer, M., Cousins, I.T., DeWitt, J.C., Goldenmann, G, Herzke, D., Lohmann, R., Ng, C.A., Trier, X.,

& Wang, Z. (2020). An overview of the uses of per- and polyfluoroalkyl substances (PFAS). Environmental Science: Processes and

Impacts, 22, 2345. https://doi.org/10.1039/D0EM00291G

Minnesota’s PFAS Blueprint • February 2021

Industry branch

Examples of uses

Electroplating

Chrome, nickel, copper, tin, and zinc plating

Energy (non-oil or gas)

Photovoltaic cells (repels dirt, highly transparent coating), coal power plants

(filters ash fly from smoke), lithium ion batteries: binder for electrodes, prevents

thermal runaway reactions, electrolyte solvent

Firefighting foam

Film former, foam stabilizer, flame retardant

Floor coverings

Soil-release finishes for carpets, stain resistant coatings, added to floor polish as

wetting agent, additive to laminated floor covering

Glass

Dirt-repellant and mist prevention, wetting agent, etching baths, solvent

displacement when drying

Laboratory supplies

Polymeric PFAS used for consumable materials like vials and caps, some columns

filter with polymeric PFAS

Leather

Water and oil resistant coatings, aids in manufacturing leather (hydrating,

degreasing)

Machinery and equipment

Coating metal surfaces, etching baths, water removal from processed parts

Medical equipment

Contrast agents in

f NMR imaging, wetting agents, emulsion additives, and

stabilizers in x-ray films, raw material for contact lenses, delivery agent for eye

drops, surgical patches, toothpaste (enhances fluoroapatite formation), dental

floss, UV-hardened dental restorative materials, artificial heart pump (blood

compatible and durable)

Mining

Ore floatation/separation, copper and gold ore leaching,

Musical instruments

Guitar strings, piano keys

Nuclear industry

Lubricants for valves and ultracentrifuge bearings in enrichment plants

Oil and gas

Foaming agent in drilling fluid, fracking fluid, pipe lining, preventing evaporation

loss during storage

Optical devices

Optical lenses with low refractive index and high transparency

Personal care products

Emulsifiers, lubricants, stabilizers in cosmetics and hair conditioners

Pesticides

Active ingredient for killing houseflies or cockroaches, antifoaming agent,

dispersant to facilitate spreading of active ingredients on insects and plant leaves,

wetting agent for leaves (PFAS is not currently used as an active or inert

ingredient in us pesticides, but may be used in packaging materials for pesticides)

Pharmaceutical industry

Reaction vessels, stirrers, and other lab equipment, polymeric PFAS as filters,

polymers used as packaging

Photographic industry

Antifoaming agent in processing solutions, wetting agent for photographic films

and papers, anti-reflective agent for paper and plates

Plastic and rubber

production

Mold lining, etching plastic, anti-blocking agent for rubber production, additive in

curatives for fluoroelastomer formation, improves weather resistance

Printing

Toner and printer ink to improve ink flow, improve wetting, aid pigment

dispersion and impart water resistance to water-based inks

Refrigerant systems

Heat transfer fluids, lubricants

Semiconductor industry

Wetting and etching agent, cleaner to remove cured epoxy resins or films, non-

stick coatings, increases photosensitivity of the photoresist layer, provides anti-

reflective coating

Sports

Ski wax (highly water repellant), weather protection of sailing boat equipment,

coatings for tennis rackets, fishing line, artificial turf

Minnesota’s PFAS Blueprint • February 2021

Industry branch

Examples of uses

Stone, concrete, and tile

Oil and water repellant coatings (improves durability, reduces oxidation of

surface)

Textile production

Wetting agent, antifoaming agent during dyeing and bleaching of textiles, dye

transfer material, emulsifying agent for fiber finishes, coating for PPE used by

firefighters

Watchmaking

Aid in drying after cleaning parts, used in lubricants

Wood industry

Coatings for food surfaces, part of adhesive resin for wood particleboard

Not all uses of PFAS in industrial settings are known. Currently, there are no requirements to label

products containing PFAS, limiting information availability. PFAS use while making a product does not

necessarily mean that the product itself contains PFAS or, if it does, that the PFAS is bioavailable.

However, even in these cases, production of the product could result in PFAS releases and disposal of

the products could result in PFAS passing through waste facilities to the environment. Although

information remains limited on where specific PFAS are used, how they are used, and why they are

used, the wide variety of applications is clear.

Where are PFAS found in the environment?

As PFAS were first emerging as contaminants of concern, the general expectation was that PFAS would

only be found (or only be found at levels of concern) at areas where they had been manufactured,

where that manufacturing waste was disposed of, or where there had been a spill or accidental release

of PFAS. However, when regulators and researchers look for PFAS in the environment using

appropriately sensitive analytical techniques, PFAS are frequently detected. The US Centers for Disease

Control and Prevention (CDC) regularly conducts the National Health and Nutrition Examination Survey,

which, among other objectives, measures levels of environmental contaminants in the blood and urine

of Americans. National Health and Nutrition Examination Survey has been including PFAS in blood and

urine monitoring since the 1999-2000 survey cycle, and finds that exposure to PFOA and PFOS continues

to be “universal,” even for Americans who were born after these PFAS were phased out of production in

the US

A recent global study of PFAS in soils (which used consistent sampling, extraction and analytical

procedures), found detections of PFAS in every soil sample, including samples from remote locations in

every continent.

PFAS are known to occur in remote areas like the Arctic, where they have been found

to accumulate in high concentrations in snow and biota due to patterns of long-range atmospheric

transport.

PFAS can exist in the gas phase or can sorb to particulate material suspended in the air –

both particulate and gaseous PFAS can transport long distances in the atmosphere.

The ubiquity of PFAS coupled with their long environmental half-lives contributes to the widespread

occurrence of PFAS in the environment and in our bodies. PFAS cannot be considered solely a problem

around areas where large quantities have been manufactured, disposed of, or spilled. PFAS are present

in nearly all parts of our environment. The breadth and diversity of PFAS pollution, coupled with a lack

of research on health impacts of many members of the PFAS family, complicates the development of

regulatory and non-regulatory approaches to managing PFAS.

Calafat, A.M., Kato, K., Hubbard, K., Jia, T., Cook Botelho, J. & Wong, L. (2019). Legacy and alternative per- and polyfuoroalkyl

substances in the US general population: Paired serum-urine data from the 2013-2014 National Health and Nutrition

Examination Survey. Environment International, 131, 105048. https://doi.org/10.1016/j.envint.2019.105048

Rankin, K. Mabury, S.A., Jenkins, T.M., & Washington, J.W. (2015). A North American and global survey of perfluoroalkyl

substances in surface soils: Distribution patterns and mode of occurrence. Chemosphere, 161, 333-341.

http://dx.doi.org/10.1016/j.chemosphere.2016.06.109

Joerss, H., Xie, Z. Wagner, C.C., von Appen, W., Sunderland, E.M., & Ebinghaus, R. (2020). Transport of legacy perfluoroalkyl

substances and the replacement compound HFPO-DA through the Atlantic Gateway to the Arctic Ocean – is the Arctic a sink or

source? Environmental Science and Technology, 54 (16), 9958-9967. https://doi.org/10.1021/acs.est.0c00228

Minnesota’s PFAS Blueprint • February 2021

What are risks from PFAS to human health and the environment?

Part of the reason that PFAS affect the body at low doses is that many of them accumulate in blood, as

many of their structures mimics common fatty acids. In pregnant women, the PFAS body burden that

has accumulated over many years can be passed to the developing fetus through the placenta and to

the infant through breast milk. Fetuses and infants are especially vulnerable to toxicants because their

body is still developing – disruptions to organ system development during this time can potentially

cause life-long impacts. The amount of time that many PFAS remain in the human body is longer than

would be expected based on observations from animal studies. This difference can complicate

interpretations of animal toxicology data and its extrapolation to human impacts. Multiple individual

PFAS exhibit toxic effects on the same organ or organ systems, like the liver. As most PFAS

contamination is likely a mixture of many PFAS, this may result in an additive toxic effect. Considerations

of total PFAS toxicity are important when assessing potential health risks.

An entirely complete dataset for toxicity and exposure is rarely available for environmental

contaminants. For obvious reasons, it is not ethical to test the effects of a toxic compound on humans.

Instead, risk assessors often reference experiments on animals. These animal studies could be of various

durations, including “chronic” studies, meaning that the experiment lasts the majority of the laboratory

animal’s expected lifetime, or studies that are “multigenerational,” meaning that the laboratory animals

are bred during the experiment, and toxic effects are observed in the pregnant animals and in the new

offspring through maturity. These chronic and multi-generational studies can be important for

identifying adverse health effects that could emerge if there is prolonged exposure to an environmental

contaminant over all stages of life, including pregnancy and infancy. These effects could include

reductions in fertility, developmental effects, and cancer. In the PFAS family, some compounds have

shown carcinogenic effects (PFOA) and others have shown sensitive immunological effects in infants

exposed during gestation and early life (such as PFOS). Other sensitive effects for PFAS include thyroid

effects, liver effects, and effects on energy metabolism. Most PFAS have data gaps in some areas of

concern – for example, many PFAS do not have chronic or multigenerational studies available, or even

shorter-duration studies measuring effects in organ systems that have been shown to be sensitive to

exposures to PFAS. Risk assessors can account for uncertainties associated with data gaps using

established risk assessment tools like uncertainty factors. For most PFAS, there are so many data gaps

that risk assessors have limited ability to draw conclusions about the amount of exposure that could

cause adverse health outcomes over a lifetime. In these cases, conducting traditional risk assessments is

not possible.

There is less information available on effects of PFAS on wildlife as there is on humans. However, it is

known that PFAS can cause toxic effects in birds, terrestrial species, and aquatic life. In birds, PFAS has

been shown to reduce the survival rates in hatchlings and in fish, PFAS has also been shown to reduce

survival rates.

There is currently significant research underway to better understand the effects of

PFAS on aquatic life, aquatic-dependent wildlife, and terrestrial wildlife.

Environment and Climate Change Canada. (2018). Federal Environmental Quality Guidelines, PFOS. Retrieved from:

https://www.canada.ca/en/environment-climate-change/services/evaluating-existing-substances/federal-environmental-

quality-guidelines-perfluorooctane-sulfonate.html

EPA (n.d.) ECOTOX Knowledgebase. Per- and Polyfluorinated Substances. Retrieved from:

https://cfpub.epa.gov/ecotox/explore.cfm?cgid=36

Minnesota’s PFAS Blueprint • February 2021

Addressing and managing PFAS

Ideally, chemicals that could cause environmental and human health concerns are regulated through the

EPA’s chemical registration program in a way that appropriately manages risk and prevents harmful

pollution. However, if there has not been proactive management through restrictions placed on a new

chemical’s use or disposal under the EPA’s chemical registration program,

addressing contaminants of

emerging concern generally begins with a discovery of the presence of the compound in drinking water,

fish, air or elsewhere in the environment. From this discovery flows research into the sources of the

compound, its patterns of occurrence in the environment, and the risks to humans or wildlife. From this

research, regulators can set risk-based values for levels of that pollutant that should not be exceeded in

the environment, and work to ensure pollution stays below those levels. Sometimes managing pollution

also involves restricting the uses of the compound, or regulating how substances are stored,

transported, and disposed of. Reducing pollution and keeping it low happens through a combination of

pollution prevention (which can be regulatory or voluntary), permitting (rules and limits on releases that

can result in treatment to remove the pollution), and other pollution reduction strategies.

In Minnesota, the first “discovery” of PFAS pollution occurred in the early 2000s, when drinking water

contamination was found in the East Metropolitan Area of the Twin Cities (East Metro). Since that

discovery, there has been a plethora of state, federal, corporate, and academic research into the toxicity

and occurrence of PFAS. Though much research is still ongoing and some data gaps remain, Minnesota is

now entering the phase of incorporating PFAS into the regular regulatory structures used for

environmental contaminants that reduce or eliminate ongoing PFAS releases and manage existing PFAS

pollution.

History of PFAS in Minnesota

Minnesota’s journey to begin managing and addressing PFAS contamination began in 2002, when 3M

alerted the MPCA of PFAS in its Cottage Grove production and drinking water wells. In 2004, 3M notified

the Minnesota Department of Health (MDH) that additional PFAS disposal sites were located in the East

Metro, and MDH began investigating potentially impacted drinking water wells in that region. In 2006,

the addition of Perfluorobutanoic acid (PFBA) to the PFAS monitoring analyte list resulted in the need

for even more widespread investigation. In all, the East Metro investigations have spanned nearly 20

years and identified an area of groundwater contamination covering over 150 square miles that impacts

the drinking water supplies of over 174,000 Minnesotans.

A public health intervention to reduce exposure to PFAS began in 2006. This effort included installing

filtration systems for polluted public and private wells, which reduced PFAS concentrations in drinking

water to levels below health-based guidance. In 2007, Minnesota and 3M agreed to a consent order

outlining that 3M is responsible for providing safe drinking water to the affected residents. Various

remediation actions were also taken to address the source of PFAS contamination at the 3M PFAS

disposal sites, including excavation of PFAS-contaminated soil and sediment or waste containment at

each of the four 3M PFAS disposal sites. Biomonitoring showed that the drinking water interventions

reduced PFAS concentrations in the blood serum of residents.

In 2010, Minnesota filed a lawsuit against 3M Company seeking payment for natural resource damages

caused by 3M’s disposal of PFAS in the East Metro. Minnesota and 3M reached an agreement to settle

EPA. (n.d.) Reviewing new chemicals under the Toxic Substances Control Act (TSCA). Retrieved from:

https://www.epa.gov/reviewing-new-chemicals-under-toxic-substances-control-act-tsca

Minnesota Department of Health (2015, December). East Metro PFC3 Biomonitoring Project, Report to the Community.

Retrieved from:

https://www.health.state.mn.us/communities/environment/biomonitoring/docs/pfc2015communityreport.pdf

Minnesota’s PFAS Blueprint • February 2021

the state’s Natural Resource Damage lawsuit in 2018. Under the terms of the agreement, 3M provided

$850 million to Minnesota to be used for safe and sustainable drinking water and natural resource

projects. After legal and other expenses were paid, about $720 million remained to invest in drinking

water and natural resource projects in the East Metro. The top priority for the grant money is to

improve the quality and quantity of drinking water in the East Metro including, but not limited to the

cities of Afton, Cottage Grove, Lake Elmo, Lakeland, Lakeland Shores, Maplewood, Newport, Oakdale,

Prairie Island Indian Community, St. Paul Park, Woodbury, and the townships of Denmark, Grey Cloud

Island, and West Lakeland. The second priority for grant spending is to enhance water resources, wildlife

habitat, and outdoor recreational opportunities in the east metropolitan area, or downstream of the

area on the Mississippi and St. Croix Rivers. Efforts to remediate impacted groundwater and surface

water continue today.

Funding from the 2007 Consent Order allowed MPCA to conduct additional investigations into PFAS in

drinking water, surface water, and fish tissue around the state. These investigations lead to the

discovery of more PFAS sources and more sites requiring PFAS remediation actions that are not related

to 3M waste disposal. This information supported the issuance of fish consumption advice for PFOS and

the development of site-specific water quality criteria for PFOS and PFOA. MPCA is now overseeing

investigations and clean-ups at sites associated with metal plating facilities, sites associated with

firefighting training and testing, and sites associated with other industries.

Present and future PFAS activity

Minnesota’s state agencies have been working to respond to PFAS and incorporate managing this

pollution into regular research, guidance, and regulatory work. However, efforts have largely been

focused around reacting to new PFAS discoveries and specific discrete concerns. More systematic

initiatives have occurred as resources arise, but have been scoped to the level of available resources.

While important work has been completed, ongoing resources are needed to allow the agencies to build

comprehensive and holistic PFAS programs. The following is Minnesota’s generally desired strategy for

PFAS management:

1. Prevent PFAS pollution wherever possible

2. Manage PFAS pollution when prevention is not feasible or pollution has already occurred

3. Clean up contaminated sites

The costs and burden of these activities increases from prevention (which may require large efforts to

establish but is relatively easy to maintain) to site clean-ups (which can be quite costly and time

consuming). The state could play different roles depending on its authorities and the stage of

management, including writing regulations to ban or restrict uses, providing technical or financial

assistance for pollution prevention, regulating PFAS through permitting or other actions, helping

educate the public about PFAS, deriving risk-based values for PFAS, and leading clean-up efforts.

PFAS represent a large and diverse class of compounds where not all structures in the group are defined

and chemical or physical properties of the compounds can be unexpected. Because regulators have

limited information about which PFAS are included in products, industrial processes, or waste streams,

before PFAS pollution can be prevented, managed, or cleaned-up, it must be discovered which

substances are occurring and where. Exploratory monitoring (both traditional quantitative monitoring

and non-targeted analytical approaches) is a key step in every stage of the PFAS response process.

PFAS exposure in over-burdened communities

Across the US and in Minnesota, communities of color and low-income communities are exposed to

higher levels of pollution than the average person. These communities also experience substantial

Minnesota’s PFAS Blueprint • February 2021

health inequities. While the state agencies are committed to promoting equity (MPCA is working on

environmental justice – making sure that pollution does not have a disproportionate impact on any

group of people

— and MDH is committed to advancing health equity

), it will take long-term systemic

changes to the ways environmental contaminants are regulated to reach these goals.

Racial and socioeconomic trends in pollution exposures are the result of historic and ongoing structural

racism in the form of inequitable governmental policies and practices. These include widespread

housing policies such as racial covenants and red lining,

and can be seen in specific projects with long-

lasting impacts, such as the destruction of Black neighborhoods to build Interstates 94 and 35.

The

increased impact of pollution on communities of color and low-income communities is especially well

documented in Minnesota in instances of air pollution,

but these inequities can manifest in many other

areas.

Studies tracking which communities are most impacted by PFAS pollution reflect similar general trends

of increased impact to communities of color and low-income communities that have been shown with

other types of pollution. Broad biomonitoring studies, like those conducted by the CDC across the entire

US , indicate that higher-income groups have historically had somewhat higher blood serum levels of

PFAS, perhaps due to higher use of non-stick cookware, higher likelihood of purchasing of stain resistant

clothing and furniture, or dietary habits that result in consuming more food with PFAS-containing

packaging.

However, considering exposure from environmental sources shows different trends. For

example, researchers from the Northeastern University’s Social Science Environmental Health Institute

recently completed an assessment using data from PFAS monitoring in Michigan.

This report revealed

that when considering 23 non-military sites known to have PFAS contamination in Michigan, about

36,000 more low-income households lived within five miles of a site contaminated with PFAS than

would be expected if there were no increased likelihood of exposure based on socio-economic status.

Similarly, approximately 134,000 more people of color lived within five miles of a site contaminated with

PFAS than would be expected if there were no increased likelihood of exposure based on race. These

trends represent a 49% increased likelihood of living in proximity to a PFAS contaminated site based on

low socioeconomic status and a 48% increased likelihood based on racial status. Though the distribution

of PFAS contamination relative to racial and socioeconomic status in Minnesota may not be identical to

that of Michigan, it is reasonable to assume that these trends may hold true throughout the US

MPCA. (n.d.). MPCA and environmental justice. Retrieved from https://www.pca.state.mn.us/about-mpca/mpca-and-

environmental-justice

MDH. (n.d.). Health Equity. Retrieved from: https://www.health.state.mn.us/communities/equity/index.html

For one example of these racially motivated policies, see the Mapping Prejudice project at

https://www.mappingprejudice.org/index.html.

Beer, T. (2019, November). Neighborhood Resistance to I-94, 1953-1965. MNOPEDIA. Retrieved from:

https://www.mnopedia.org/event/neighborhood-resistance-i-94-1953-1965; Minnesota Department of Transportation. (n.d.)

Rethinking I-94 and Twin Cities Public Television. Interstate 94: A History and Its Impact. Retrieved from:

https://www.dot.state.mn.us/I-94minneapolis-stpaul/background.html (accessed 7/23/2020)

A Public History of 35W, https://35w.heritage.dash.umn.edu/ (accessed 7/23/2020)

Institute on Metropolitan Opportunity, University of Minnesota. Redlining in the Twin Cities in 1934: 1960s and Today.

https://umn.maps.arcgis.com/apps/MapSeries/index.html?appid=8b6ba2620ac5407ea7ecfb4359132ee4 (accessed on

7/27/2020)

MPCA. (n.d.) Understanding environmental justice in Minnesota. Retrieved from:

https://mpca.maps.arcgis.com/apps/MapSeries/index.html?appid=f5bf57c8dac24404b7f8ef1717f57d00

Buekers, J., Colles, A., Cornelis, C., Morrens, B., Govarts, E., & Schoeters, G. (2018). Socio-economic status and health:

evaluation of human biomonitored chemical exposure to per-and polyfluorinated substances across status. Environmental

Research and Public Health, 15, 12, 2818. doi: 10.3390/ijerph15122818

Northeastern University, Social Science Environmental Health Research Institute, The PFAS Project Lab. (2019, October 31)

PFAS Contamination Is an Equity Issue, and President Trump’s EPA Is Failing to Fix It. Retrieved from:

https://pfasproject.com/2019/10/31/pfas-contamination-is-an-equity-issue-and-president-trumps-epa-is-failing-to-fix-it/

Minnesota’s PFAS Blueprint • February 2021

PFAS exposure, however, is not simply a matter of proximity to a contaminated site. Certain

communities of color and low-income communities may be at a higher risk of PFAS exposure due to

factors like higher rates of local fish consumption. Similarly, low-income groups may be less able and

less likely to pay for things like home drinking water systems that filter PFAS. PFAS-free items may not

be marketed to these groups. Communities of color and low-income communities may be more likely to

have older carpeting, furniture, cookware, clothing or other products containing PFAS like PFOS and

PFOA that have now been phased out of use. In general, these communities are likely to be more

susceptible to adverse health impacts due to historical disenfranchisement, disinvestment, and

disproportionate exposure to pollution.

Reversing these racial and socioeconomic disparities in exposure to PFAS will require proactive efforts

on the part of policy makers and regulators across a broad range of public policy spaces. Efforts to

dismantle the deeply-rooted structural racial and economic inequities that cause disproportionate

burdens of pollution should be included in every project Minnesota agencies undertake. The issue

papers included in this document aim to discuss opportunities to advance environmental justice and

health equity within each PFAS topic area.

PFAS summary and needs

The issue papers following in this report will describe the many PFAS initiatives taken in Minnesota and

those currently underway, and identify key areas of opportunity for moving forward on managing and

addressing PFAS. The papers also highlight the significant interconnections and overlaps between

different areas, illustrating the complexity and difficulty of managing PFAS. The papers are intended to

provide a shared grounding in past work and open spaces for discussion about future needs. The

discussion of future opportunities focuses primarily on those that could be undertaken in Minnesota

through actions by the state agencies or the Legislature, though in some cases deferring to federal

agencies for action may also be an option. Minnesota will continue to collaborate closely with state and

federal partners to leverage each other’s data and learn from each other’s scientific and regulatory

experiences.

Minnesota’s PFAS Blueprint • February 2021

Background

 Pollution prevention (P2) approaches are designed to reduce exposure to toxic chemicals and prevent

the need for expensive treatment and remediation efforts.

 P2 approaches can be regulatory or voluntary. Examples include manufacturers reformulating

products to eliminate or minimize use of toxics or consumers purchasing products with safer, less

persistent alternatives.

 P2 approaches are especially important for managing PFAS: all PFAS are resistant to environmental

degradation or transform to PFAS that are persistent in the environment.

 Continued use of PFAS results in increased loading to the environment, making it more likely that,

over time, PFAS reach levels associated with toxic effects in humans and damage to ecosystems.

 PFAS concentrate in effluent, biosolids, landfill leachate, and composting contact water.

Removing PFAS using treatment technology requires cutting-edge, complex, multi-step processes

that are often cost prohibitive for the businesses and municipalities that operate waste facilities.

 Because PFAS are resistant to destruction, treatment and management strategies often remove

PFAS from one media only to transfer them, along with their risks and potential liabilities, to

another.

 Chemical use regulations mainly occur at the federal level. EPA regulates chemicals under the Toxic

Substances Control Act (TSCA), which was passed in 1976 and significantly amended in 2016. The TSCA

amendments were intended to place responsibility on chemical producers to prove new chemicals are

safe before they can be registered for use.

 Many PFAS were registered prior to the 2016 TSCA amendments, and limited to no data on

toxicity to humans or ecosystems are available. However, even under the new TSCA rules, many

PFAS are continuing to be registered for use without publicly available environmental safety

information.

 There are many challenges in implementing P2 policies for PFAS.

 PFAS is a broad class of compounds used in many industries – some estimate thousands could

exist in the environment – and available analytical methods measure only a small portion of total

PFAS.

 Toxicity, use, and release data for many PFAS are considered “confidential business information,”

and are often not available to the public.

 Some PFAS uses are essential for functions in society (for example, PFAS uses for protective

equipment used by medical professionals), increasing the importance of nuanced and tailored

regulatory approaches.

What is Minnesota doing now?

 Minnesota has banned the use of PFAS-containing firefighting foams for training or testing purposes,

and is working with fire departments and others to encourage use of fluorine-free firefighting foams

(F3) during emergencies.

 MPCA has amended state contracts (used by agencies, universities, cities, counties, municipalities, and

non-profits) to remove compostable products containing PFAS.

Preventing PFAS Pollution

Summary

Minnesota’s PFAS Blueprint • February 2021

What are remaining gaps and opportunities for action?

Filling gaps to better support preventing PFAS pollution would require legislative action for agencies to

gain new authorities or secure additional resources. The opportunities described below are ideas – based

on successes implemented in the past for other compounds (DDT, Polychlorinated biphenyls (PCBs), etc.)

or implemented for PFAS in other states and international agencies – that would require additional

planning and discussion before they could be moved into action.

 Gap: In many cases, PFAS are not providing an essential purpose and could be banned without

significant impact to society (i.e., PFAS used in ski wax or food packaging).

 Opportunity: Lawmakers could ban PFAS uses that are currently known to be non-essential,

such as PFAS used for food packaging. Additionally, MPCA could create a workgroup that

would further define “essential,” “substitutable,” and “non-essential” uses of PFAS. With the

recommendations of this workgroup, legislators or regulators could more easily devise a

strategy for tackling PFAS pollution prevention based on the “essential use” framework.

 Gap: Currently, many businesses and consumers are using PFAS-containing products but are not

aware that they are doing so, or are not aware of the potential health risks and liabilities

associated with them.

 Opportunity: MPCA could consider proposals for mandatory labeling of PFAS in products,

which would help business owners and individuals make environmental, health-conscious, and

business-friendly purchases while encouraging manufacturers to pursue alternatives to PFAS.

 Opportunity: MPCA could provide technical and financial assistance to business to reduce

PFAS pollution. Existing frameworks (e.g. MnTAP, Small Business Grant Program) could be

expanded to implement PFAS reduction strategies.

 Gap: Government agencies and other groups using state purchasing contracts have significant

spending power and can model environmentally-friendly supply chain practices. Many materials

purchased using these contracts contain PFAS.

 Opportunity: Minnesota could remove all products with PFAS serving a non-essential use from

state purchasing contracts.

How does this work benefit human health and the environment?

 Discouraging PFAS use subsequently reduces opportunities for PFAS exposure, which improves

the health of humans and the environment.

 Pollution prevention techniques improve health of workers in businesses with PFAS use and

reduces exposures in other vulnerable groups with the highest pollution burdens.

How does this work benefit Minnesota’s economy?

 P2 strategies reduce liability for businesses and reduce the need for costly site clean-ups.

 PFAS alternatives may be better and cheaper, potentially improving profitability for businesses.

 Waste facility operators have limited ability to control PFAS inputs. P2 measures decrease loading

of PFAS to waste facilities, and ultimately to the environment.

 Farmers across the country have been burdened with PFAS contamination of milk, livestock, and

produce despite having no intentional PFAS uses on their land. P2 measures protect farmers by

reducing PFAS levels in biosolids, animal feed, surface water, soil, and groundwater.

Minnesota’s PFAS Blueprint • February 2021

Background

Compounds with some of the most notorious legacies for causing harm to human health and the

environment, like PCBs, dioxins and arsenic, share a common trait – persistence. Though PFAS include a

variety of structures with a variety of physical and chemical properties, all PFAS are either themselves

incredibly resistant to degradation in the environment or degrade to other PFAS that are persistent. As a

result, continued use of PFAS in industry and in commercial products will necessarily result in increased

loading of these chemicals to the environment over time. As concentrations increase in water, fish, soil,

air, and in human bodies, it becomes increasingly likely that environmental concentrations of PFAS will

meet levels associated with adverse health effects in humans or adverse outcomes in ecosystems.

Preventing the pollution from these persistent compounds is necessary to ensure that negative

outcomes for human health and the environment do not continue to manifest.

Pollution prevention

Environmental regulations are generally designed to encourage treating pollutants where they are

emitted or discharged so that they are not released into the environment – whether that be air, water,

or soils. However, some persistent pollutants can be extremely difficult and expensive to treat either at

the source of pollution (like at an air stack or discharge pipe) or at outputs from facilities like landfills,

wastewater treatment plants, or composting sites. Well-intentioned pollution control and management

solutions sometimes remove pollutants from one media only to transfer them, and their potential

liabilities, to another. P2 approaches may involve manufacturers taking steps such as product

reformulation to eliminate or use less of a toxic chemical, commercial users replacing a product with a

safer, less persistent alternative, or industrial users reducing chemical waste production through better

training or preventing spills and leaks. When implemented successfully, P2 approaches can also often be

more resource and energy-efficient for manufacturers, producing significant savings while reducing

liability and damage to the environment.

P2 for PFAS

PFAS are ubiquitous in consumer products and have applications spanning many industrial sectors.

There are many types of industrial facilities that may be discharging PFAS to water or emitting PFAS to

air, where it has been shown to deposit on soils and surface waters

Options are limited for PFAS

control systems in facilities that are emitting PFAS from stacks – research has shown that no control

technologies are effective at fully removing PFAS emissions and no control technologies are effective for

all types of PFAS.

Once PFAS-containing products are removed from the manufacturing process, at

some facilities residual PFAS emissions may continue despite efforts to clean equipment and replace

ductwork. The many challenges associated with controlling emissions of PFAS at facilities indicates that

avoiding PFAS use in industrial contexts is likely the most effective way for industrial users to limit

liability and for regulators to manage potentially harmful releases.

Due to widespread use in industrial and commercial products, PFAS can concentrate to significant levels

in waste like effluent, biosolids, landfill leachate, and composting contact water. Consumer products

containing PFAS such as clothing, food packaging, carpeting, and other materials have been shown to

significantly contribute to PFAS loading into leachate, effluent, biosolids, and composting contact water

Prevedouros, K., Cousins, I.T., & Buck, R.C. (2006). Sources, Fate and Transport of Perfluorocarboyxylates. American Chemical

Society, 40(1), 32-44. https://doi.org/10.1021/es0512475

EPA. (2019) PFAS Environmental Contamination Associated with Manufacturing Sites in New Hampshire. Retrieved from:

https://www4.des.state.nh.us/nh-pfas-investigation/?p=1019

Minnesota’s PFAS Blueprint • February 2021

when they are eventually discarded.

Removing PFAS from waste products using treatment technology

requires cutting-edge, complex, multi-step processes that are often cost-prohibitive for the businesses

and municipalities that operate these types of facilities. In many cases, treatment of PFAS from waste

like leachate ends up simply transferring PFAS back into a landfill, where it may move back into leachate,

requiring additional costly treatment. Preventing PFAS from entering waste facilities in the first place is

key to stemming releases. Though pollution prevention cannot reduce the PFAS in commercial products

already in circulation, preventing new PFAS from entering commerce going forward will help tackle the

challenge of managing ongoing PFAS emissions from industrial sources and PFAS discharges from waste

facilities in the years ahead. This prevention of PFAS pollution to waste facilities will likely require that

industrial and consumer products containing unnecessary PFAS be phased out of use.

When PFAS are released to the environment, humans may be exposed and the PFAS may adversely

impact ecosystems, contaminating groundwater, surface water, and soils. Once PFAS has polluted a site,

remediating the water and soil to meet health-based guidance levels has proven to be exceedingly

expensive. Sometimes driving PFAS concentrations in environmental media (like surface water) down to

health-based standards is not possible with currently available technologies. Given the widespread use

of PFAS in industry and commercial products, using site remediation as the main tool for environmental

risk reduction is not feasible or strategic. Pollution prevention is a better long-term choice.

This issue paper discusses the work Minnesota has already completed to reduce PFAS use in the state,

and outlines some of the many remaining gaps and opportunities for new policy, research, and agency

actions towards pollution prevention.

Chemical use regulation

The rules and regulations that have the largest impacts on PFAS pollution prevention currently occur at

the federal level. The EPA regulates chemicals used in commerce under the TSCA, which was passed in

1976 and was significantly amended in 2016. Under the original TSCA rules, the onus to prove that a

compound should not be allowed (or registered) for use because of concerns over biological or human

health rested with the EPA. The amendments to TSCA passed in 2016 revised the law to place

responsibility on chemical producers to prove their new chemicals were safe for use before they are

registered. The EPA restructured the TSCA program into a section that reviews new chemicals (seeking

registration after the 2016 TSCA amendments) and a section that reviews existing chemicals (registered

before the 2016 TSCA amendments). Many PFAS were registered for use in the US before the new TSCA

rules went into place, and as a result limited or no data on their toxicity to humans and ecosystems are

available. However, even under the new TSCA rules, many new PFAS are continuing to be registered for

use in the US without toxicity data requirements or publicly available environmental safety information.

Part of this failing under the new TSCA program stems from how EPA has managed the new chemical

approval program to date.

There have been several paradigms proposed to determine which compounds should be allowed for use

in commerce and which compounds should receive extra regulatory scrutiny before they are registered.

Many of these ideas are being applied to registration applications for new chemicals, but agencies in the

US and internationally are also applying these frameworks retroactively to chemicals introduced into

commerce and industry before modern rules were put in place. The process of reviewing the thousands

of existing chemicals in commerce and industry is time consuming and, in most instances, has only

recently begun.

Vermont DEP. (2019). PFAS Waste Testing Report for New England Waste Services of Vermont. Retrieved from:

https://dec.vermont.gov/pfas

Minnesota’s PFAS Blueprint • February 2021

The most common framework is that compounds that are persistent, bioaccumulative and toxic (or

PBTs) need extra scrutiny. This is the framework used to prioritize compounds for review under TSCA.

Under the PBT paradigm, a compound must have all three characteristics before it is considered a

compound of high concern. While this strategy captures many compounds of high concern, there are

other compounds that are only known to have only one or two of these characteristics that should

perhaps receive additional scrutiny. That includes compounds that have low relative toxicity but persist

and bioaccumulate to a degree that toxic thresholds can eventually be exceeded after prolonged

exposure.

The European Chemicals Agency, the European Union’s regulatory authority over chemical registration,

implements a regulation called Registration, Evaluation, Authorization and Restriction of Chemicals

(REACH). In general, the European Union’s approach to chemical registration is more precautionary than

EPA’s TSCA program and requires more upfront identification of risks. REACH recognizes the limitations

of relying on PBT classification alone, and also uses a paradigm for escalating review of compounds that

are “very persistent and very bioaccumulative” - called vPvB. The chemical registration program in

Canada takes a similar approach to REACH, and will require “virtual elimination” of certain uses of

compounds should risks associated with persistence and bioaccumulation be identified.

These

paradigms escalate review of compounds that bioaccumulate and persist in the environment but have

either low or unknown toxicity.

While the PBT and vPvB strategies would capture a large percentage of PFAS currently in use in

commerce, perhaps justifying use restrictions or bans, advocates for additional reform in chemical

registration frequently take the position that manufactured compounds that are simply “very

persistent” should also require significant additional scrutiny regarding the necessity of use before they

are allowed into commerce. This approach, shorthanded as the “p-sufficient” approach, would identify

all PFAS because they are all either very persistent or transform to other persistent PFAS.

The p-

sufficient approach does not rely on complete knowledge of a compound’s potential for

bioaccumulation or its potential toxicity to sensitive subpopulations like developing fetuses (information

that is rarely captured in toxicity studies submitted during chemical review) if the compound is known to

be excessively persistent in environmental media, thereby posing a high risk of human exposure.

Unless the state were to pass new legislation authorizing the development of chemical use regulations

in Minnesota, chemical registration will continue to be controlled by federal authorities. Minnesota

could advocate that EPA move towards approaches that would result in extra scrutiny on more PFAS as

they are evaluated for ongoing or new use, like the vPvB or “p-sufficient” approaches used in other

countries.

Despite limited influence over the chemical registration processes in the US, Minnesota has other

mechanisms for managing PFAS use and preventing additional pollution. Minnesota has already banned

the use of PFAS-containing firefighting foams for training or testing purposes, a measure that will

substantially decrease PFAS emissions to surface waters, soils, and groundwater.

Other legislative

actions could be considered that would put in place bans or restrictions for other PFAS uses in the state

and mandate labeling of PFAS in products.

Environment and Climate Change Canada. (2017). Canadian Environmental Protection Act: virtual elimination. Retrieved at:

https://www.canada.ca/en/environment-climate-change/services/canadian-environmental-protection-act-registry/general-

information/fact-sheets/virtual-elimination.html

DeWitt, J., Gluge, J., Goldenman, G., Herzke, D., Lohmann, R., Miller, M., Ng, C.A., Scheringer, M., Vierke, K. & Wang, Z.

(2020). Strategies for grouping per- and polyfluoroalkyl substances (PFAS) to protect human and environmental health.

Environmental Science: Processes Impacts, 22, 1444-1460. Doi: 10.1039/D0EM00147C

MPCA. (n.d.) PFAS in firefighting foam. Retrieved from: https://www.pca.state.mn.us/waste/pfas-firefighting-foam

Minnesota’s PFAS Blueprint • February 2021

Considering highly exposed groups when planning PFAS P2 initiatives

Minnesotans in communities already overburdened with pollution due to past policies motivated by or

resulting in racial and socioeconomic discrimination, may also be at an increased risk of experiencing

higher exposures to PFAS. This compounded exposure to multiple types of environmental pollutants

may exacerbate adverse health effects observed in these communities. Studies have shown that people

from cultures with traditional hunting and fishing diets have high concentrations of long-chain PFAS in

their blood due to PFAS bioaccumulation in game and fish.

Though PFAS contamination in Minnesota

drinking water has spanned communities with different racial and socioeconomic profiles, individuals

within those communities who rely on locally caught fish and game as a source of healthy protein for

themselves and their families are the most likely to have high levels of exposure to long-chain PFAS like

PFOS. There are also some individuals exposed to PFAS through their job, like firefighters, who may have

added exposure from environmental routes. It is important that decisions regarding allowed use of PFAS

consider risks to those who are likely to have the highest exposure.

Challenges to preventing use and release of PFAS

There are many challenges associated with preventing PFAS pollution. Firstly, PFAS is a broad class of

compounds used in many industries. We know that standard methods frequently measure only a small

portion of total PFAS in the environment.

Because most PFAS are difficult to measure in environmental

media, it is hard to prioritize PFAS that have existing approved uses for additional regulatory review

based on occurrence of the compound. The classification of much PFAS use data, release data, and

toxicity data as “confidential business information” additionally hinders prioritization efforts. With this

limited information for prioritization and a huge number of PFAS, it can be difficult to know where to

start with pollution prevention efforts. The industries that produce PFAS and use PFAS have found them

to be profitable, which complicates efforts to impose restrictions or bans. Despite these challenges, it is

important to remember that each effort to reduce PFAS loading to the environment results in fewer

sites requiring costly remediation down the road, fewer people being exposed to dangerous levels of

pollution, and a healthier environment.

Past and ongoing efforts

The following sections describe completed and ongoing work related to reducing PFAS loading to the

environment. So far, this work has focused on encouraging safer alternatives to PFAS-containing firefighting

foams and eliminating some PFAS-containing products from Minnesota purchasing agreements.

Removing PFAS-containing products from Minnesota contracts for compostable products

MPCA works closely with the Department of Administration’s Office of State Procurement to provide

products on state contracts that are environmentally preferable. In addition to state agencies,

universities, cities, counties, municipalities, and non-profits are all eligible to use these state contracts.

In 2017, Office of State Procurement and MPCA created a contract for compostable food service items

(e.g. plates, cups, utensils, take out containers) that included specifications restricting the use of PFAS in

Caron-Beaudoin, E., Ayotte, P., Clanchette, C., Muckle, G., Avard, E., Ricard, S., & Lemire, M. (2020). Perfluoroalkyl acids in

pregnant women from Nunavik (Quebec, Canada): Trends in exposure and associations with country foods consumption.

Environment International, 145, 106169. https://doi.org/10.1016/j.envint.2020.106169

Chem, F., Ericksson, U., Aro, R., Yeung, L., Kallenborn, R., & Karrman, A. (2018 Screening of per- and polyfluoroalkyl substances

(PFAS) and total organic fluorine in wastewater effluent from Nordic countries [Conference poster]. SETAC 2018 Convention,

Rome, Italy. Retrieved from:

https://www.oru.se/contentassets/7afa1d1a8df7415a9498720de4151d41/setac_rome_2018_chen_screening-of-per--and-

polyfluoroalkyl-substances-PFAS-and-total-organic-fluorine-in-wastewater-effluent-from-nordic-countries.pdf

Minnesota’s PFAS Blueprint • February 2021

products offered. Concurrently, the Center for Environmental Health (CEH), an independent non-profit

organization, was conducting testing for a report on PFAS in compostable foodware.

The CEH used a total

fluorine method to estimate if there was likely added PFAS to compostable products. If results indicated

“high fluorine,” meaning the product had at least 10-fold higher levels of fluorine than a “low fluorine”

product, CEH suggested that the product likely contained fluorine additives in the form of PFAS. CEH’s

testing indicated that many compostable products on the state contract claiming to not contain PFAS

actually did contain added PFAS. Upon learning the results of the CEH testing, MPCA followed up with

vendors regarding the products believed to contain PFAS. The vendors confirmed that PFAS were added.

With this information, Minnesota was able to remove the PFAS-containing products from the state

contract. Minnesota was also able to stipulate that any products offered on the contract were required to

have accompanying test results indicating low or no fluorine levels going forward. While this decreases the

purchase and use of PFAS containing products at state agencies and other entities, these PFAS-containing

compostable food service items are still available in the consumer market.

Work status: completed

Leaders: MPCA RMAD Sustainable Materials Management Unit, Minnesota Department of

Administration, Office of State Procurement. Partner: Center for Environmental Health.

Benefits: Removing PFAS from supply chains, particularly sources to composting facilities, is

beneficial for several reasons. Waste facilities concentrate water-soluble and mobile PFAS – like

PFOS, PFOA, Perfluorohexane sulfonate (PFHxS), and PFBA – from commercial products into

leachate and contact water. MPCA recently completed a study of PFAS in contact water collected at

composting facilities that found elevated levels of PFAS in all participating facilities’ contact water.

The largest source of PFAS in facilities accepting food waste is suspected to be grease-resistant

coatings on compostable foodware products. These facilities do not have treatment technologies in

place to remove PFAS from leachate or contact water before it is discharged to the environment.

Furthermore, because leachate and contact water are rich in organic matter, these wastewaters can

be especially difficult to treat. A PFAS treatment system may not be economically feasible for some

individual waste facilities, including composting facilities. Preventing PFAS from entering these

facilities is the most cost-effective method of preventing their ultimate release into the

environment. The restrictions on the state purchasing contract reduce loading of PFAS to

Minnesota’s composting facilities.

The effort to remove PFAS-containing products from purchasing agreements has the additional

benefit of creating an economic incentive for companies to find safer alternatives to PFAS products

and reduce PFAS in their own supply chains. Minnesota’s efforts to inquire about PFAS additives

signaled to compostable product producers that PFAS is problematic and will not be accepted as an

additive by many high-volume buyers. This effort additionally contributed to a decision by the

Biodegradable Products Institute – a compostable product certification – to begin screening for PFAS

and restrict PFAS use in certified products.

Challenges: On the state’s disposable (non-compostable) foodware contract, equivalent PFAS

restrictions have not yet been incorporated. A separate effort is needed to remove PFAS containing

products from this contract as well as from other state contracts offering product categories that

are known to contain PFAS.

Resources: This effort required staff time from MPCA’s RMAD Sustainable Materials Management

unit and the Department of Administration, Office of State Procurement, but no additional

resources.

Center for Environmental Health. (2018). Avoiding Hidden Hazards, a purchasers guide to safer foodware. Retrieved from:

https://www.ceh.org/wp-content/uploads/2019/05/CEH-Disposable-Foodware-Report-final-1.31.pdf

MPCA. (n.d.). Composting and PFAS. Retrieved from: https://www.pca.state.mn.us/waste/composting-and-pfas

Minnesota’s PFAS Blueprint • February 2021

Encouraging the use of fluorine-free firefighting foams

PFAS-containing firefighting foams are used to extinguish fires of liquids like oil, fuel, or flammable

solvents. Foams that are designed to put out these fires of flammable liquids are called “Class B

firefighting foams.” PFAS have historically been used in these products because of their surfactant and

oxygen-scavenging properties. However, uses of PFAS-containing Class B firefighting foams (which

include aqueous film-forming foams or AFFF) have proven to be some of the largest known contributors

of PFAS releases to the environment. This ongoing initiative by the MPCA aims to encourage entities to

transition away from PFAS-containing foams towards fluorine-free firefighting foams (F3), ideally F3 that

are also free of other chemical hazards. The MPCA has encouraged Class B firefighting foam

manufacturers to certify their fluorine-free products with third-party environmental health and safety

certifiers (e.g., GreenScreen). Additional outreach to users of Class B firefighting foam is ongoing.

Work status: ongoing

Leaders: MPCA Resource Management and Assistance Division and Remediation and Emergency

Response Unit. Partners: State Fire Marshal, fire service and user associations, the Interstate

Chemicals Clearinghouse, partner states, standard-setting and testing entities like GreenScreen.

Benefits: Though PFAS-containing firefighting foam has already been banned for most testing and

training purposes in the state, ending all uses of PFAS-containing foam, including in actual fire

emergencies, would reduce a substantial source of PFAS release to the environment. Additionally,

facilitating the transition to F3 will reduce the long-term expense to firefighting departments of

safely managing and disposing of discharged or unused PFAS-containing foams.

Challenges: Encouraging use of F3 is challenging for several reasons. There are some federal

requirements that firefighting foams containing fluorine (i.e. PFAS) must be available to extinguish

Class B fuel fires at some Department of Defense (DoD) and airport facilities. Congress has directed

the Federal Aviation Authority to no longer require fluorinated foams at airports by 2021 and has

also directed the DoD to establish an updated firefighting foam standards and performance testing

requirements by 2024 so that PFAS-containing firefighting foams are no longer used by 2029. To

date, F3 have not fully met the existing military performance specifications needed to fight certain

Class B fires.

Currently, there are a limited number of certified F3 products available for private and government

purchasers. Increasing the number of certified foams will take time. MPCA and partners will also

have to overcome resistance to F3 among the firefighting community. Early F3 were not perceived

to perform as needed (partially due to lower quality products in the early days of alternative foam

development and partially due to limited training for firefighters on using F3), cementing the false

belief the F3 would never perform as needed for Class B fires. Overcoming this negative perception

will be aided by the planned new military specification and alternatives research currently being

undertaken by the DoD.

Resources: This effort requires time from MPCA staff to conduct research and outreach, but no

project funding.

Gaps and opportunities

There are many gaps in effectively managing PFAS to prevent harmful pollution. Many of these gaps

would require legislative action for Minnesota agencies to gain new authorities or secure additional

resources. For this reason, the projects described below are ideas of ways that Minnesota could advance

work on preventing PFAS pollution in the state, based on successes in managing other persistent,

bioaccumulative compounds in the past and successes in other states and international regulatory

agencies in regulating PFAS. Many of these ideas would require additional planning and discussion

Minnesota’s PFAS Blueprint • February 2021

before they could be moved into action. In some cases, it may be determined that state action is not

feasible or strategic but that Minnesota should push for or support broader federal action to support

similar goals.

As described in the background of this issue paper, chemical registration and use regulation currently

primarily rests with the EPA. Minnesota statutes contain bans for certain types of chemicals and

products (such as PCBs, or bisphenol A and formaldehyde in children’s products), but no explicit bans on

PFAS. The Legislature could consider banning or restricting uses of PFAS, or could grant the MPCA the

authority to review and restrict uses of PFAS or other pollutants of concern in commercial and industrial

products. Alternatively, MPCA could continue to lobby the EPA to consider improved TSCA regulations

for PFAS.

Many groups have proposed regulations such as use restrictions or bans on certain PFAS, but these

groups also acknowledge that some applications of PFAS are important for the health and safety of

society. The lack of knowledge about which PFAS applications are critical or “essential” (like using PFAS

for protective equipment in surgical operating rooms, where no other existing technologies provide

equivalent safety and effectiveness) and where they could be replaced with safer alternatives (like PFAS

in water-resistant surfing shorts or cosmetics) makes it challenging to focus on the best opportunities to

replace already-registered PFAS uses. There are opportunities to make progress by conducting a

prioritized alternatives analysis for the PFAS in uses that are causing the largest environmental impacts.

This effort would involve determining essential use criteria that could be used for coordinated chemical

regulation. However, there is also a gap in available information and knowledge of which products

contain PFAS due to a lack of federal reporting requirements. This makes it difficult to conduct reviews

of existing PFAS uses.

The lack of transparency about which products contain PFAS also prevents businesses and individuals

from engaging in voluntary P2 strategies like limiting or ending their purchases of PFAS-containing

products. Requirements for labeling PFAS-containing products would help inform the public. Labeling

requirements would also be useful if Minnesota were to make additional efforts to remove PFAS-

containing products from state purchasing contracts.

Finally, there may be opportunities to provide financial or technical assistance to help businesses

transition away from using PFAS-containing products using the existing infrastructure at MPCA to issue

grants and provide technical assistance to businesses. These suggestions for potential opportunities to

fill the identified gaps are described in more detail in the action proposals below.

Regulate PFAS using a framework of essential, substitutable, and non-essential uses

PFAS are used in a multitude of products and industries around Minnesota. In some cases, PFAS are not

providing an essential use and could be banned without significant impact to society. For example,

though fluorinated cross country ski waxes are more effective than alternatives at repelling water for

fast skiing, recreational and professional cross country skiing is entirely possible without PFAS-

containing waxes. In fact, international cross country ski races have already banned PFAS-containing

waxes in their competitions based on concerns about human health and ecological impacts. Sufficient

research exists to ban some of these clearly non-essential PFAS uses currently. However, for other uses

of PFAS, analysis would be required to determine if safer alternatives to PFAS exist that could fill the

need. Under this proposal, MPCA would create and lead a workgroup tasked with creating a framework

for future regulation of PFAS-containing products based on “essentiality” criteria. In general, an

“essentiality” framework groups products into the following three categories:

Minnesota’s PFAS Blueprint • February 2021

1. Non-essential – not essential for health and safety and the functioning of society.

2. Substitutable – now-familiar uses that perform useful functions but for which there are feasible and

demonstrated-safe alternatives, rendering PFAS use non-essential.

3. Essential – considered necessary for health and safety or other very important purposes, where

safer alternatives to PFAS are not feasible or available.

This effort would likely involve identifying the highest priority PFAS uses in Minnesota and evaluating

safer alternatives to PFAS in families of essential PFAS applications. A model for this work is Washington

State’s 2018 revisions to its Toxics in Packaging law, which required Washington’s Department of

Ecology to undertake an alternatives analysis for each application of PFAS in food packaging and

determine availability of feasible alternatives. Once the Department of Ecology publishes a report or

findings that an alternative is feasible and available for a specific application, the law prohibits the sale

of PFAS containing food packaging two years after the date of publication of the report.

In 2019, Maine

banned PFAS in food packaging, effective January 2022, drawing on their conclusion that PFAS was

unnecessary in food packaging.

In 2020, New York also banned PFAS in food packaging, effective

January 2023.

The potential for a ban on PFAS-containing food packaging is discussed in more detail in

the Limiting PFAS Exposure from Food Issue Paper.

With the recommendations of this workgroup and documentation of PFAS alternatives assessments for

high-priority uses, legislators in Minnesota could more easily devise a strategy for tackling PFAS

pollution prevention through law and policy based on an “essential use” framework. For example, the

Legislature could phase out sales and importation of some PFAS products that fit into a non-essential

use category, require end of life stewardship programs for products that fall into essential use

categories, or authorize MPCA to regulate PFAS in this way.

Work status: under consideration, actions on recommendations would require legislative involvement

Leaders: MPCA Resource Management and Assistance Division. Partners: Interested participating

agencies or partner states.

Benefits: Alternatives analysis is an important step in determining if PFAS product bans or voluntary

phase-outs are feasible – PFAS bans would have the direct benefit of reducing environmental

release of PFAS, which corresponds to decreased exposure to humans and other ecological

receptors. Any effort to conduct alternatives analysis and designate PFAS uses based on

“essentiality” criteria would require expertise from many technical, regulatory, and industry experts.

By including a variety of experts the workgroup, perhaps even including partner states, Minnesota

would be more likely to have access to the relevant experts to propose an “essentiality” framework

that is feasible, fair, and reasonable for multiple industries.

Challenges: Some parties feel that product bans or restrictions are most effectively managed by the

federal government. While federal bans may be the most effective, lack of federal action thus far

means states motivated to reduce harmful loading of PFAS in their water, soil, and air are looking for

other options. Currently there are no labeling or reporting requirements for PFAS use in industry on

commercial products and the structures and uses of many PFAS are considered proprietary

information. For this reason, there is a large data gap on which industries or products use PFAS, and

for what purposes. Pending changes to federal laws on this topic, for the workgroup to be

WA Toxics in Packaging Law - Chapter 70.95G RCW; 2018 revisions in Engrossed Substitute House Bill 2658, Chapter 138,

Laws of 2018.

Maine Act to Protect the Environment and Public Health by Further Reducing Toxic Chemicals in Packaging – Chapter 277,

2019. Retrieved from: http://www.mainelegislature.org/legis/bills/display_ps.asp?ld=1433&PID=1456&snum=129.

An Act to amend the environmental conservation law, in relation to the use of perfluoroalkyl and polyfluoroalkyl substances

in food packaging. Retrieved from: https://www.nysenate.gov/legislation/bills/2019/s8817.

Minnesota’s PFAS Blueprint • February 2021

successful, there would likely need to be collaboration with many industries in the state to provide

information on the PFAS uses. Even then, there would likely still be significant data gaps for products

produced outside of Minnesota. Fleshing out the definitions of each “essentiality” category and

sorting known PFAS uses into those categories would likely be time consuming and contentious.

Anticipated resource needs: The effort would require considerable staff time, primarily at the

MPCA. A staff position to help coordinate PFAS pollution prevention activities would also be

important for a successful outcome.

Require labeling of PFAS-containing products

An additional P2 initiative would be requiring all PFAS-containing products to include a disclosure on the

product or package indicating that the product contains PFAS. Design considerations for this policy

would include:

 If the producer of the product would be required to disclose the specific PFAS structures

included and in what quantities they are included

 If the producer of the product would be required to submit the PFAS composition information to

a centralized database

 If there would be any minimum thresholds for mandatory reporting to account for inadvertent

PFAS inclusion (such as PFAS inadvertently included in recycled paper)

 How such a labeling policy would be enforced

This labeling would allow consumers to be alerted to the potential exposure to PFAS from the products.

Currently, many businesses are using PFAS-containing products but are not aware that they are doing

so, or are not aware of the potential health risks and legal liabilities associated with them. Labeling of

PFAS in products would help business owners make smart environmental, health conscious, and

business-friendly purchases. Additionally, many landfill operators, WWTPs, and composting facilities are

currently struggling to identify the sources of PFAS into their facilities. Mandatory labeling of PFAS in

products and reporting of the quantities would help waste facility operators make decisions about which

products to accept at their facilities. Finally, this labeling would encourage manufacturers to pursue

preferable alternatives to PFAS.

Work status: under consideration – action on any policy recommendations would require legislative

involvement

Leader: MPCA Resource Management Assistance Division.

Benefits: Overall, product labeling for PFAS would help individuals, businesses, and government

entities reduce PFAS exposure and emissions while also increasing demand for products that contain

safer alternatives to PFAS. Labeling would inform purchasing decisions and end of life management

decisions regarding disposal options.

Challenges: Industries that produce PFAS or PFAS-containing products will likely oppose this effort,

especially because no international, federal or state governments have yet mandated such labeling.

Enforcement of labeling requirements will also require resources to test and confirm claims. An

education effort would also likely needed for the public so they can understand what any required

label is conveying.

Resources: Though researching the policy proposal for this effort requires relatively limited staff

time, should this proposal be implemented, significant resources would be required to coordinate

and enforce the rules.

Minnesota’s PFAS Blueprint • February 2021

Develop public sector purchasing guidelines to end purchases of PFAS-containing products

Government agencies and other groups using state purchasing contracts have significant spending

power and can model environmentally-friendly supply chain practices. MPCA has worked with the

Department of Administration to remove PFAS-containing products from Minnesota’s contract

purchasing agreements. To date, these efforts to restrict PFAS have been focused on compostable

products like compostable food containers and serviceware, where PFAS is added to repel water and

grease from the product surface. Many other items, including stain-repellent carpeting or furniture,

have been shown to contain PFAS. This project seeks to expand on the existing work to remove PFAS

from supply chains by excluding PFAS from all non-essential uses in any product purchased using state

contracts. These purchasing guidelines could be used as a model for private groups or individuals

intending to reduce PFAS purchasing.

Work status: under consideration

Leaders: MPCA Sustainable Materials Management Unit and the Department of Administration

Office of State Procurement.

Benefits: MPCA and others have documented that PFAS from compostable and disposable products

are making their way into compost facilities, landfills, and eventually the environment. Expanding

work on removing PFAS from contract purchasing agreements would reduce overall loading of PFAS

to waste facilities, reduce demand for PFAS-containing products when PFAS is not necessary, and

incentivize product manufacturers or vendors to produce less toxic and less persistent alternatives

to PFAS.

Challenges: This effort would be challenging for several reasons. When there are not PFAS labeling

requirements in place, it is difficult to ascertain which products contain PFAS without laborious efforts

to contact producers and verify claims. With or without labeling requirements in place, prioritizing

which state contracts offer the most PFAS-containing products would be necessary. Considerations

would be needed to not restrict purchases of PFAS-containing products that fall into essential use

categories, like protective equipment for healthcare workers. Additional effort would be needed to

ensure accountability so product manufacturers do not distribute PFAS-containing products in

violation of the contract terms. Education would likely be needed to explain why such reductions in

PFAS purchasing would be necessary given that sometimes alternatives can be more costly.

Resources: This effort would require staff time from MPCA Sustainable Purchasing Program and the

Department of Administration, Office of State Procurement. This work would be most efficient if

conducted in coordination with other efforts proposed above, including defining essential use

categories for PFAS. If such an effort to reduce PFAS purchasing across many contracts were to be

undertaken, funding for product testing may be needed.

Consider providing financial and technical assistance to businesses for switching from PFAS-

containing products

PFAS are ubiquitous in products that may be used in many industries around Minnesota, from car

washes to metal plating facilities. Some businesses may not even be aware that they are using, and

possibly emitting or discharging, PFAS-containing products. MPCA has multiple existing programs that

provide financial or technical assistance for existing and new businesses that seek to improve

environmental performance and prevent pollution.

For example, the MPCA small business grant

program provides funding opportunities to business facilities and community organizations across

Minnesota to improve their systems while reducing overall environmental burden. The Minnesota

Technical Assistance Program (MnTAP), located at the University of Minnesota, provides on-site and

MPCA. (n.d.). Technical Assistance. Retrieved from: https://www.pca.state.mn.us/quick-links/technical-assistance

Minnesota’s PFAS Blueprint • February 2021

telephone assistance, interns, an information clearinghouse, and a coordinating role in the state

materials exchange program.

The proposed project would allow the current technical and financial

assistance programs to incorporate PFAS reduction intro their programs.

Work status: under consideration – would require additional funding

Leaders: MPCA Business Assistance Unit.

Benefits: By providing financial and technical assistance, businesses are given the incentive to switch

from PFAS to a preferable alternative. By doing so, businesses are also put in a position to make a

more economically feasible choice for their operations and serve as an environmental leader within

their industry. The development of this program would increase the awareness about PFAS in many

industries, which would lead to further PFAS emission reductions. Incorporating PFAS reduction

strategies into existing programs that help businesses to find safer alternative chemistries will

increase demand for these safer alternatives and encourage more innovation in green chemistries.

Challenges: One existing technical and financial assistance programs, the Small Business Grant

program, is largely focused on air pollutant reduction due to its present funding source. While the

Business Assistance Unit has the capacity to administer additional grants targeting PFAS not related to

air emission reduction, additional funding must be made available to achieve that goal. Consultation

with green chemistry experts at MPCA and MnTAP would be needed to ensure that replacement

products for PFAS do not contain “regrettable substitutions” with other environmental concerns.

Anticipated resource needs: Funding will be needed to provide financial and technical assistance to

businesses. Projects would largely involve a switch from products that include PFAS to a preferred

alternative. Grant funding would also be available for equipment needs.

Overview of intersectional issues

 Managing PFAS in waste: Landfill leachate, effluent and biosolids from WWTPs, and contact

water from composting facilities all contain PFAS stemming from industrial and commercial uses

of PFAS-containing products. Preventing pollution of PFAS will reduce the regulatory burden of

waste facility operators to manage PFAS waste when they have limited control over PFAS

entering their facilities. The carbon-fluorine bonds in PFAS are extremely difficult to destroy.

Though new technologies are being invented to improve options for PFAS destruction, these

technologies at this time are often expensive, energy intensive, and not available at large scale.

 Protecting drinking water: Treating drinking water for PFAS contamination is very costly for

municipalities and private well owners. Even when drinking water meets health-based criteria,

consumers often demand that no PFAS be detected in their water at all. Preventing pollution of

groundwater, one of Minnesota’s most precious natural resources, will prevent the need for

treatment and other interventions to reduce PFAS exposure from drinking water in the future.

 Reducing exposure from fish and game consumption: PFAS can be emitted to air or discharged to

water, ultimately contaminating surface water, soil, and plants. This contamination can cause high

concentrations of certain PFAS to accumulate in fish, deer, and other commonly consumed game.

Preventing pollution of PFAS will ensure that those who hunt in Minnesota, either for sport, as

part of their cultural heritage, or for subsistence, are not exposed to harmful levels of PFAS.

 Remediating PFAS-contaminated sites: Cleaning up sites that have already been polluted with

PFAS is costly and time intensive. In some cases, technology does not yet exist to remediate

contaminated media to levels that meet health-based guidelines. Preventing the need for PFAS

site remediation is the strategic approach to PFAS moving forward.

University of Minnesota. (n.d.). Minnesota Technical Assistance Program. Retrieved from: http://www.mntap.umn.edu/

Minnesota’s PFAS Blueprint • February 2021

AS effectively and consistent

Background

 The first step in managing pollution is understanding which pollutants occur in the environment,

where, and at what levels. This work requires effective sampling techniques and established

analytical methods.

 If methods are not available or if detection limits make it impossible to determine if PFAS are

exceeding protective levels, it presents challenges to risk assessment and regulation.

 Although early focus on PFAS method development was on drinking water, there are now PFAS

methods for multiple media -- several new EPA methods are also in development.

 The Public Health laboratory at MDH is capable of measuring PFAS in multiple media, including

biological matrixes, soils, and water.

 Agencies can also contract with private commercial labs to run analyses for PFAS.

 Costs associated with PFAS analysis are generally $300 - $400 per sample.

 Despite progress in method development, it is not possible to quantitatively measure the vast majority

of PFAS – available methods represent less than 1% of all PFAS in the environment.

 Knowing what to look for: Many new PFAS are currently being designed by chemical companies

and registered for use at the EPA – information about these compounds is often considered

“confidential business information” and not publicly available.

 Designing new approaches: Developing new PFAS methods is time consuming and uncertain.

Some new ideas and techniques are successful, but many fail. It can be difficult to predict how

much time developing a new method will take and the detection limits a method will be able to

achieve.

 Measuring at levels relevant to human and environmental health: As toxicologists learn more

about PFAS toxicity, health protective concentrations have decreased, sometimes to levels below

what analytical methods can reliably detect.

What is Minnesota doing now?

 MDH’s Public Health Lab (PHL) continues to develop and improve PFAS analytical methods.

 PHL developed a simple PFAS method for drinking water and groundwater, created PFAS methods

for dust, soil, and vegetables, and developed and improved methods to measure PFAS in blood

serum, plasma, and breastmilk.

 PHL validated the newest EPA drinking water method for PFAS (EPA Method 533), which will allow

PHL to support testing for the next round of EPA-mandated drinking water monitoring (UCMR5).

 MPCA and MDH have multiple efforts underway to ensure consistent and accurate PFAS analytical

results, whether work is done by Minnesota staff or others.

 MPCA is collaborating with EPA Office of Research and Development (ORD) on PFAS sample

collection strategies.

 MPCA continues revising the PFAS Analytical Guidance document.

 MPCA and MDH are considering changing the way that labs are accrediated for PFAS in the MDH

lab accreditation program (MNELAP).

Measuring PFAS effectively and consistently

Summary

Minnesota’s PFAS Blueprint • February 2021

What are remaining gaps and opportunities for action?

 Gap: With potentially thousands of PFAS occurring in the environment, the vast majority of PFAS

are not currently included in analytical methods. Further, it is difficult to know which PFAS should

be targeted for method development – companies are not required to report the PFAS they

produce or use in all cases, and if the information is reported to EPA, it is often protected as

“confidential business information” and not released.

 Opportunity: A technique called non-targeted analysis allows researchers to identify hundreds

of chemicals in a sample at one time. Increasing availability and accessibility to non-targeted

methods in public labs would help prioritize method development, improve site investigations,

and generally improve the understanding of the entire landscape of PFAS mixtures present in

environmental media.

 Non-targeted analysis requires technical and laborious data processing, as well as instruments

that are in high demand for many competing projects. Increasing capabilities for non-targeted

analysis could require purchasing or renting additional instruments and hiring of staff with

expertise in non-targeted methods for PFAS.

 Gap: The current toolbox of analytical methods is effective at measuring a discrete number of PFAS

at low detection limits. Other tools may be more cost-effective and efficient in contexts where

precise measurements of many PFAS analytes are not necessarily required.

 Opportunity: Minnesota could consider researching and possibly adopting screening methods

for PFAS in public labs.

 Aggregate PFAS methods measure groups of PFAS and have been applied in scenarios like

screening-level analysis of environmental media or in rapid analysis to determine if PFAS is

present in a consumer product. Examples of aggregate PFAS methods include total organic

fluorine (TOF) analysis and particle induced gamma emission analysis (PIGE). Total oxidizable

precursor (TOP) analysis measures the increase in some terminal PFAS degradate

concentrations in a sample after precursors are chemically transformed, which provides total

PFAS precursor concentrations for those terminal degradates.

 Another option for PFAS screening methods could involve developing simple PFAS methods

that are faster and cheaper to run at scale than existing methods, but look for a small number

of PFAS likely to be risk-drivers in a given site (often analytes like PFOS, PFOA, and PFHxS).

How does this work benefit human health and the environment?

 The ability to measure PFAS allows MDH and MPCA to identify exposures, which is necessary to

protect human health and prevent negative environmental outcomes.

How does this work benefit Minnesota’s economy?

 In-house method development allows Minnesota agencies to design methods relevant to the state,

which can save time and money during research projects or site investigations.

 Getting ahead of issues of environmental releases by monitoring for PFAS with advanced methods

would allow MPCA to be proactive, potentially preventing PFAS emissions before costly remediation

efforts are needed.

Minnesota’s PFAS Blueprint • February 2021

Background

The first step of managing pollution is understanding which pollutants occur in the environment, where,

and at what levels. Answering these questions requires sampling techniques and analytical methods that

allow chemists to accurately and reliably measure presence and levels of pollutants. These pollutants

could be present in commercial or industrial products and various environmental media like water, air,

soil, and biota. Sampling techniques focus on how samples of media (air, water, soil, fish tissue) are

collected and stored so that they accurately represent the environmental conditions. Effective sampling

techniques ensure that the way samples are collected and transported does not add additional pollution

or cause existing pollution to go unmeasured (for example, from contaminants sticking to the sampling

container). The preferred sampling methods for PFAS in different environmental media have evolved

over time as researchers have learned more about PFAS. Analytical methods describe how media are

analyzed in a lab to determine the levels of pollutants present in a sample. In order to compare results

from multiple labs, EPA will sometimes publish “EPA approved methods” that are proven to give the

same results regardless of which lab is using them, but EPA is often slow to develop, validate, and

publish these methods. MDH’s PHL and commercial labs also develop reliable and robust PFAS methods,

in many cases before any EPA approved methods for the PFAS analytes in a given media are available.

There are now a variety of types of analytical methods for PFAS that are designed to answer different

questions – this diversity of methods is helpful in ensuring researchers and regulators have a full toolbox

for environmental work. Standard analytical methods are media and chemical-specific. They enable the

lab to measure the specific amount of specific pollutants in a sample, and they will only detect those

pollutants. These methods can change over time as techniques and technology improve, usually

resulting in detection of more types of pollutants and lower levels of pollutants. These standard

methods (looking for levels of specific PFAS) are expensive and only include a small subset of all PFAS,

but they give results that allow environmental programs to determine if specific PFAS remain below

levels that may cause adverse impacts to human health and the environment. For these programs,

availability of standard analytical methods is critical. When standard methods are not available for a

certain compound in a certain media, or when detection limits make it impossible to determine if the

level of PFAS in samples exceed protective levels in all cases, it presents challenges to risk assessment,

regulating pollution, and reducing pollution. Newer analytical techniques for PFAS have emerged that

may help answer different questions than the standard pollutant-specific approaches. For example,

some analytical techniques can be used to determine if PFAS have been added to a product. Other

techniques can return a concentration of a group of PFAS. Some techniques can determine if a large

number of individual PFAS are present, but cannot determine the concentrations of those PFAS.

Together, standard analytical methods and these newer analytical techniques provide a useful toolbox

for PFAS management.

History of method development for PFAS

Analytical methods for PFAS are relatively new and actively developing. In the early 2000s, PFAS were

not understood in the way they are now -- as ubiquitous and toxic chemicals. The chemists with the

tools to measure PFAS were mainly those working for the chemical companies that produced them.

When MPCA was notified about PFAS contamination in drinking water in the East Metro, the state PHL

had to quickly develop their own new method for measuring them. The PHL first developed a method to

measure two PFAS (PFOA and PFOS) in water, and then expanded that method to include seven PFAS,

albeit with relatively high detection limits. That meant that if any of the seven PFAS in the method

occurred below the detection limit, they would not be measured, and if any other PFAS were present, it

would not be known. At the time, there were no other commercial or public labs measuring PFAS in

drinking water or any other media.

Minnesota’s PFAS Blueprint • February 2021

Over time, as attention to PFAS contamination has grown, the analytical methods used to measure them

have improved. From measuring two PFAS, methods improved to measure 13 compounds, and they are

still improving. Newer methods can measure around 40 PFAS with detection limits many times lower

than the ones in early PFAS methods. Although most focus and advancement has been on methods for

detecting and measuring PFAS in drinking water, there are now at least some methods for PFAS in

multiple media. This includes methods for “clean” water like treated drinking water, “dirty” water like

surface water and wastewater, biological media like fish tissue and blood serum, and solid media like

soils, dust, and vegetables. EPA-approved methods for many matrices are in development.

These

improvements in our capability to see PFAS in lower concentrations and in more media has been one of

the major reasons why PFAS are now known to be ubiquitous in everything from tree leaves to the

blood of Americans around the country.

Despite this progress in method development, scientists are still in the unfortunate position of not being

capable of quantitatively measuring the vast majority of PFAS. There are over 5,000 PFAS with defined

chemical structures that exist – some are compounds intentionally produced for use in industry and

commerce, but others are products of transformation within the environment or byproducts of

manufacturing. Many more PFAS structures are being designed by chemical companies every day. The

PFAS that we can measure represent less than 1% of all PFAS in the environment. In addition, as

toxicologists learn more about the toxic effects of some PFAS, the concentrations of PFAS that MDH has

determined to be health protective have been decreasing over time, in some cases to levels that are

below what analytical methods can reliably detect in the relevant media. To address ongoing interest in

a wider variety of PFAS, chemists have begun to develop new approaches to measuring larger groups of

PFAS. Each of these new approaches has benefits and limitations when compared to traditional

analytical methods.

Role of the MDH Public Health Lab in PFAS method development

The PHL at MDH was established in 1873 as a chemical laboratory to test water and food.

Today, the

lab has evolved into a sophisticated facility capable of testing thousands of samples a day, including

samples containing potentially hazardous substances. MPCA also has laboratory facilities capable of

measuring environmental contaminants in air and water to support its programs, but does not conduct

PFAS analysis. The MDH PHL provides a critical resource to Minnesota in addressing public health

concerns, including the development of analytical methods when no standard method is available. MDH

and MPCA have the PHL available as an in-house partner for research and monitoring projects. Working

with public labs has many advantages including ease of collaboration, full transparency over exactly how

and when samples are tested, and the assurance that there are no potential conflicts of interest at play.

MPCA has samples processed in the PHL or sends them to commercial labs. Commercial labs can run

methods that are not available at the state labs, covering more analytes and more media. The public

labs also have significant demands on their services, and sometimes contracting with private labs results

in capacity to run larger numbers of samples for large projects.

Benefits of non-targeted analysis in PFAS investigations

Traditionally, analysis of environmental pollutants is compound-specific. Concentrations are determined

by comparing the signal from the sample to the signal from solutions made by chemists where the

specific compound in question has a known concentration (analytical standards). Due to the large

number of PFAS and the lack of analytical standards for many of them, research scientists are working to

EPA. (n.d.). PFAS Analytical Methods Development and Sampling Research. Retrieved from: https://www.epa.gov/water-

research/pfas-analytical-methods-development-and-sampling-research

MN Health. (2018, Feb 28). The Public Health Laboratory [Video file]. Retrieved from:

https://www.youtube.com/watch?v=45q7rxSAsEg&feature=emb_logo

Minnesota’s PFAS Blueprint • February 2021

develop new strategies to try to identify and measure more PFAS. One strategy is a technique called

“non-targeted analysis.” In essence, non-targeted analytical techniques use high-resolution mass

spectrometers to collect structural information called “spectra” on all chemicals in the sample and use

software to match the signal from the sample to the signals of thousands of known chemicals. Then, if

analytical standards are available, chemists can later confirm the identity or concentration of the PFAS

that is suspected to be present in the sample. Though non-targeted analysis provides information about

the presence of more PFAS in a given sample, this technique does not provide information about the

concentration of each PFAS in the sample. Despite this limitation, non-targeted analysis can be very

useful in various contexts. Non-targeted analysis can be used to inform which PFAS are present in

samples and in what proportion, thereby helping prioritize the development of traditional analytical

methods or procurement of analytical standards that could be used to collect concentration data.

Knowing which structures are present in various samples can also inform information requests for

toxicity data or production data on compounds that would otherwise be protected as “confidential

business information.”

Non-targeted approaches have already discovered significant and high-profile instances of PFAS

pollution that would have otherwise gone undetected due to the lack of traditional analytical methods

and monitoring. The discovery of “Gen-X” compounds, which are new PFAS chemistries developed by

DuPont as a replacement for PFOA, was due to chemists conducting non-targeted analysis of river water

downstream from the production plant.

Similarly, the discovery of a new class of chlorinated PFAS that

have widely contaminated soils in the northeastern US through air emission and subsequent deposition

was through non-targeted analysis of soils.

This information about previously unknown or unidentified

PFAS in the environment is crucial to advance understanding of PFAS impacts and exposure potential.

Currently the PHL has the ability to conduct non-targeted PFAS analysis (and has done so on some water

samples), but may have capacity limitations to do so on a regular basis. The instruments available in the

lab for non-targeted analysis are used for many other projects, and there is limited time on the

instrument to conduct these types of analyses. Additionally, conducting non-targeted analysis is still a

relatively niche specialty. MDH is lucky to have some of this expertise on using non-targeted analytical

techniques on PFAS in house, but more staff with this knowledge would be needed to conduct non-

targeted analysis with frequency.

Benefits of PFAS screening methods

While traditional analytical methods for PFAS are crucial for many applications, using them to analyze

PFAS samples is often quite expensive ($300-400 per sample), takes considerable time to complete, and

does not capture all PFAS that could exist in the sample. In order to get around some of these

challenges, chemists have proposed several possible options for reducing costs to run samples, reducing

time and effort to run samples, or increasing the ability to measure more PFAS. Firstly, there could be

opportunities to develop simple PFAS methods that are faster and cheaper to run at scale, but only look

for a small number of PFAS that are thought to drive risk in a scenario. If the goal is to estimate the total

amount of PFAS in a given sample, but not necessarily the composition or concentrations of each PFAS

present, methods like TOF analysis could be used to quantify large groups of PFAS in environmental

samples. Another newer PFAS method, called TOP analysis, is used to determine the total concentration

of PFAS precursors that transform to persistent “terminal degradation PFAS” like PFOS, PFOA, and

Sun, M., Arevalo, E., Strynar, M., Lindstron, A., Richardon, M., Kearns, B., Pickett, A., Smith, C., & Knappe, D.R. (2016) Legacy

and Emerging Perfluoroalkyl Substances Are Important Drinking Water Contaminants in the Cape Fear River Watershed of

North Carolina. Environmental Science & Technology Letters. (3) 12: 415-419. https://doi.org/10.1021/acs.estlett.6b00398

Washington, J., Rosal, C.G., McCord, J.P., Strynar, M.J., Lindstrom, A.B., Bergman, E.L., Goodrow, S.M., Tadesse, H.K., Pilant,

A.N., Washington, B.J., David, M.J., Stuart, B.G., & Jenkins, T.M. (2020). Non-targeted mass-spectral detection of

chloroperfluoropolyether carboxylates in New Jersey soils. Science, 368, (6495), 1103-1107. Doi: 10.1126/science.aba7127

Minnesota’s PFAS Blueprint • February 2021

PFHxS. Though TOP analyses do not measure the individual PFAS precursors, the approach provides

information to understand if increases in concentrations of terminal PFAS in a material, like wastewater,

could be observed as PFAS precursors oxidize over time. Currently, EPA is developing approved methods

for TOF and TOP – it is not yet clear how low detection limits may be for these methods, though existing

TOP approaches have similar detection limits as standard methods for the terminal degradate PFAS.

Other options for grouped PFAS analysis include methods like PIGE analysis. PIGE is a rapid screening

method (capable of processing over 20 samples per hour) that can measure the presence of total

fluorine in the surface of solid samples, such as samples of food packaging or textiles.

This method

could be useful identifying if products have added PFAS and in prioritizing samples or sites for further

analysis.

These screening methods for PFAS may be helpful to answer questions in some investigation

scenarios, but may not have the precision needed for many other applications.

Ensuring consistency of PFAS results

Regardless of who collects and analyzes a sample, the results of that sample should be the same. To

ensure consistency across projects and ensure that samples are taken in a way that is reflective of

environmental conditions, sampling protocols must be followed. MPCA has developed a guidance

document for PFAS analysis that includes recommendations for accurate sampling techniques. However,

as scientists learn more about PFAS fate and behavior in the environment, strategies for sampling

environmental media continue to evolve. MPCA regularly updates this document to reflect the most up-

to-date science. In addition to using consistent sampling protocols, another tool to ensure reproducible

and accurate PFAS results is to work with accredited labs. Labs can be accredited by EPA to run EPA-

approved methods (the PHL is accredited by EPA), but MDH also has a lab accreditation program that

allows contract labs in Minnesota to apply for accreditation for PFAS.

Challenges associated with developing and implementing PFAS methods

There are many challenges associated with developing and implementing PFAS methods. Existing

methods for PFAS are complex – they measure a broad range of PFAS with very diverse physical and

chemical properties that, for other classes of compounds, would likely be measured using many

different methods. The widespread use of PFAS in commercial products means that samples can be

easily contaminated. Extra care is needed to ensure no PFAS-containing materials are used in the lab or

when collecting samples in the field, and many “blank” samples – designed to detect inadvertent lab or

field-based introduction of PFAS -- are needed.

In Minnesota’s public lab and in private contract labs, PFAS analysis is expensive. Sample analysis runs

between $300 and $400 per sample. Additionally, maintaining supplies of the reagents used to run

those methods is expensive. Innovative approaches that could result in reduced effort to run PFAS

samples, or a focus on the individual PFAS that are risk-drivers within PFAS mixtures, could reduce the

overall cost of monitoring. Of course, understanding which PFAS are risk drivers requires a complete

understanding of which PFAS are present and corresponding toxicity information – currently this

information is incomplete.

Developing new PFAS methods is time consuming and uncertain. When developing methods for new

PFAS, sometimes it is difficult to procure analytical standards needed for method development. Like any

research venture, some new ideas and techniques are successful, but many fail. It can be hard to know

how much time developing a new method will take, and very difficult to predict outcomes like the

McDonough, C.A., Guelfo, J.F., & Higgins, C.P. (2019). Measuring Total PFAS in Water: the Tradeoff between Selectivity and

Inclusivity. Curated Opinions Environmental Science and Health, 7, 13-18. doi:10.1016/j.coesh.2018.08.005.

Ritter, E.E., Dickinson, M.E., Harron, J., Lunderberg, D.M., DeYong, P.A., Robel, A.E., Field, J.A., & Peaslee, G.F. (2017). PIGE as

a screening tool for Per- and polyfluorinated substances in papers and textiles. Nuclear Instruments and Methods in Physics

Research, 407, 47-54. DOI: 10.1016/j.nimb.2017.05.052

Minnesota’s PFAS Blueprint • February 2021

detection limits that the method will be able to achieve. Without knowing which PFAS are released into

the environment, it is impossible to know if methods in development are targeting the PFAS posing the

most significant health risks. In Minnesota’s public labs, it has taken several full-time staff between one

and two years to develop new PFAS methods. When the PHL develops new methods, these projects are

nearly always completed as part of a collaboration with funding for a corresponding project aiming to

measure PFAS.

Past and ongoing efforts

The following projects have been completed by MPCA and MDH, or are currently underway at those

agencies. Overall, the PHL has contributed significantly to the state’s ability to respond to PFAS

contamination in the environment, especially in the early days of PFAS investigations when private

contract labs did not have the capabilities to run PFAS samples. The PHL was one of the first to develop

PFAS methods for water and went on to be one of the first labs to develop methods for biological

samples like blood serum and vegetables. Ongoing efforts to validate methods that have been recently

approved by the EPA (such as EPA Method 533) and to expand the lab’s ability to measure PFAS in

biological samples like breastmilk are continuing to grow the public lab’s ability to measure PFAS moving

forward.

Minnesota agencies have also worked to develop scientifically robust techniques for collecting PFAS

samples and ensuring consistent PFAS measurement results, regardless of who is taking the sample and

analyzing the results in a lab. In this effort for consistency, MPCA has published a PFAS Analytical

Guidance document and updates the document regularly. MPCA is also continuing to learn more about

improvements in sampling strategies and is working with partners in EPA’s Office of Research and

Development to leverage the most recent research on this topic.

Developing and improving PFAS analytical methods

Developed simple PFAS method for drinking water or groundwater

In 2006, MDH PHL (at the request of MPCA’s Remediation program) developed a method to detect

seven PFAS in drinking water. Aqueous samples are diluted with a solvent and analyzed using High

Performance Liquid Chromatography/Mass Spectrometry (HPLC-MS/MS). This method takes about six

hours to run a batch of 20 samples.

Work status: completed

Leaders: MDH Public Health Lab.

Benefits: Having access to in-house analysis for PFAS allowed MPCA and MDH to investigate

drinking water contamination efficiently in house before commercial labs had PFAS methods

available. Though newer methods have the ability to measure more PFAS at lower detection limits,

the MDH PHL continues to use this method for its relative ease of sample preparation and its

robustness (meaning that it is accurate when scaled to run with many samples at a time). This

method is used for projects testing drinking water, surface water, and wastewater samples.

Challenges: The biggest challenges encountered while developing this method included the lack of

analytical standards – or solutions of PFAS with known concentrations to compare against the

samples with unknown concentrations – for the PFAS in the method. An additional challenge was

ensuring that there were no PFAS-containing instrument components and equipment in the lab that

may compromise samples.

Resources: It took two staff approximately two years to develop this method.

Minnesota’s PFAS Blueprint • February 2021

Developed and improved methods to measure PFAS in blood serum, plasma, and breastmilk

In 2007, MDH was directed by a Minnesota state law to conduct pilot-scale biomonitoring in two

communities likely to be exposed to PFAS. This study was developed to understand how the drinking

water PFAS exposure was impacting PFAS levels in resident’s blood. In total, three biomonitoring studies

were conducted in 2008, 2010, and 2014.

MDH’s PHL has worked with other divisions within MDH to

develop methods to support biomonitoring of PFAS in the East Metro. These methods have been used

to support other programs, including processing biomonitoring samples for federal research projects run

by the National Institute of Environmental Health Sciences. MDH initially developed a method for the

analysis of seven PFAS in blood serum and have since added capacity for eight additional PFAS analytes.

Over time, MDH has continued to update and improve these methods, aiming to increase the number of

samples that can be processed without interruption. MDH has validated the method to include blood

plasma and breastmilk in addition to serum. Current efforts involve improving the method for PFAS

analysis in breastmilk.

Work status: ongoing

Leaders: MDH Public Health Lab. Partners: MDH Chronic Disease and Environmental Epidemiology.

Benefits: With the development of these biomonitoring methods in Minnesota’s PHL, the state now

has the capacity to do PFAS biomonitoring without relying on contract labs, of which there are a

limited number capable of measuring PFAS in biological media. This allows Minnesota to be self-

reliant and fully transparent about method results with the community. The PHL has also been able

to leverage these methods to help other communities understand their exposures. Developing and

maintaining these methods has allowed MDH to include specific PFAS that are of interest in our

community. For example, PFBA is an important contaminant in the East Metro but is not commonly

included in commercial biomonitoring methods.

Challenges: Blank contamination and finding clean materials have been challenges. The existing

methods for PFAS biomonitoring did not include the short-chain analytes mandated by

biomonitoring legislation, so PHL had to develop those capabilities. As new PFAS are discovered,

more sensitive analytical equipment may be needed to do analysis.

Resources: The effort to develop this method required the time of one lab staff for about one year,

and approximately $100,000 in funding for supplies and service time for the initial method

development. Staff were trained at the CDC for method development. Over time, this method was

revisited to improve various aspects, which resulted in additional effort. The instrument (which cost

~$500,000) used to measure these samples was acquired through the Public Health Emergency

Preparedness Fund, Laboratory Response Network.

Developed PFAS methods for dust, soil and vegetable matrices

The MDH PHL developed methods for the detection of PFAS in dust, soil, and fruit and vegetable

matrices in support of the “Perfluorochemicals in Homes and Gardens Study” (PIHGS). This study

investigated PFAS found in homes in the East Metro that had drinking water contaminated with PFAS. In

these homes, treatment was removing PFAS from tap water used for drinking, but PFAS were still

present in water used for gardening and other non-drinking purposes. In support of this project, the

MDH PHL developed multiple methods for detecting PFAS in various solid matrices. The vegetable

method detected seven PFAS in a wide variety of different types of home-grown produce, each with

different sample preparation and analysis concerns. The soil method measured seven PFAS in soil taken

from the garden. The Perfluorochemicals in Homes and Gardens Study was also concerned about

potential PFAS exposure from dust. Dust was collected from the entryway and one additional room of

MDH. (n.d.). East Metro PFAS Biomonitoring Projects. Retrieved from:

https://www.health.state.mn.us/communities/environment/biomonitoring/reports/index.html

Minnesota’s PFAS Blueprint • February 2021

each house. The dust method developed by the PHL analyzed for 12 PFAS, which allowed investigators

to consider potential exposure contributions from garden soil tracked-in from the outdoors and PFAS in

household items like carpeting making its way into dust. This study was conducted in 2010 and journal

articles including method information were published in 2018 and 2019.

Work status: completed

Leader: MDH Public Health Lab. Partners: MDH Site Assessment and Consultation and MPCA.

Benefits: The development of these methods for analyzing PFAS in solid matrices allowed

Minnesota to directly respond to the concerns of citizens over the safety of consuming produce

grown in their home gardens. Developing the method at the MDH PHL was necessary because few

methods existed with the ability to analyze the wide variety of vegetable produce that home

gardeners cultivate in Minnesota. This project also provided linked soil and dust data, which were

useful in assessing if outside irrigation with contaminated water was leading to increased track-in of

PFAS to the house. This was to assess potential exposure risks for small children, who are most

highly exposed to soil and dust.

Challenges: The most significant challenge associated with developing these methods was finding

blank matrices (samples that contain no PFAS to ensure that the instrument is correctly reporting)

for dust samples. It was not possible to find PFAS-free dust, so researchers used clean sand as a

blank matrix instead. Finalizing a sample collection method for dust was also challenging. At first,

researchers intended to use dust from a vacuum cleaner, but the sieving of the vacuum cleaner

contents resulted in dust going airborne, causing concerns about contamination between samples.

Instead, dust was collected using device called a dust cartridge. There were also difficulties

developing methods that would work for all of the vegetable matrices in the study. Some vegetables

have high acid content, others have high water content or low water content. The final methods

used for this study segregated the produce into four categories with four different methods for

analysis based on the traits of the produce.

Resources: Development of methods for these three varied matrices took significant staff and

instrument time, relationships with other PFAS investigators, and upfront costs for reagents and

supplies.

Validated EPA Method 533 for drinking water

In December of 2019, EPA published a new method for measuring PFAS in drinking water called Method

533: Determination of Per- and Polyfluoroalkyl Substances in Drinking Water by Isotope Dilution Anion

Exchange Solid Phase Extraction and Liquid Chromatography/Tandem Mass Spectrometry.

If used in

combination with EPA’s previous drinking water method for PFAS (Method 537.1), these methods can

detect 29 PFAS.

EPA reference methods are used for regulatory purposes and for monitoring programs

like the mandatory Unregulated Contaminant Monitoring Rule (UCMR) under the Safe Drinking Water

Act. Validating new methods requires the laboratory to demonstrate that it can generate accurate and

Scher, D.P., Kelly, J.E., Huset, C.A., Barry, K.M., Hoffbeck, R.W., Yingling, V.L., & Messing, R.B. (2018). Occurrence of

perfluoroalkyl substances (PFAS) in garden produce at homes with a history of PFAS-contaminated drinking water.

Chemosphere, 196, 548-555. https://doi.org/10.1016/j.chemosphere.2017.12.179

Scher, D.P., Kelly, J.E., Huset, C.A., Barry, K.M., & Yingling, V.L. (2019). Does soil track-in contribute to house dust

concentrations of perfluoroalkyl acids (PFAAs) in areas affected by soil or water contamination? Journal of Exposure Science &

Environmental Epidemiology, 29, 218-226. https://doi.org/10.1038/s41370-018-0101-6

EPA. (2019). Method 533: Determination of Per- and Polyfluoroalkyl Substances in Drinking Water by Isotope Dilution Anion

Exchange Solid Phase Extraction and Liquid Chromatography/Tandem Mass Spectrometry. Retrieved from:

https://www.epa.gov/dwanalyticalmethods/method-533-determination-and-polyfluoroalkyl-substances-drinking-water-

isotope

EPA. (2019). Comparing EPA Analytical Methods for PFAS in Drinking Water. Retrieved from:

https://www.epa.gov/dwanalyticalmethods/comparing-epa-analytical-methods-pfas-drinking-water

Minnesota’s PFAS Blueprint • February 2021

precise data through an instrument calibration, verification of the calibration, demonstration of low

background analyte levels, analysis of laboratory controls that meet accuracy and precision criteria, a

method detection limit study, and confirmation of the reporting limits. MDH’s PHL validated this new

EPA PFAS method, which means that it will be able to conduct monitoring for the EPA’s UCMR program

and increase PFAS analytical capacities for other Minnesota monitoring programs.

Work status: completed

Leader: MDH Public Health Lab.

Benefits: Having the PHL validated and equipped to run EPA Method 533 is beneficial because it will

expand the laboratory’s capabilities by increasing the number of PFAS analytes from 7 to 26 and

achieve lower reporting limits. This capability would allow MPCA and MDH to send more samples to

the PHL, and therefore rely less on commercial laboratories to for these sample analyses.

Challenges: There were several challenges faced when validating EPA Method 533. To achieve the

reporting limits desired for this method, the laboratory purchased a new instrument. Setting up the

new instrument and ensuring its components were as PFAS-free as possible was a difficult and time-

consuming process. Additionally, optimizing an instrument for 26 analytes and their respective

internal standards while learning new instrument software added to the time required to get the

instrument operational. The sample preparation for EPA Method 533 is much more labor intensive

than the simple seven-analyte “dilute and shoot” method PHL has been using and presented other

challenges to the method validation. It was necessary to confirm that all aspects of the sample

extraction procedure met performance standards and were free from PFAS contamination.

Resources: It took two staff approximately 11 months to complete method development and

validation.

Efforts to ensure consistent and accurate PFAS analytical results

Collaborating with EPA Office of Research and Development on PFAS sample collection strategies

MPCA is currently working to investigate and remediate a region of surface water and groundwater

contamination in the East Metro called the Project 1007 Corridor (See Remediating PFAS-contaminated

Sites Issue Paper). This clean-up effort is one of the most complex and large-scale PFAS surface water

remediation efforts undertaken in the US Because many elements of this investigation and clean-up are

new, MPCA staff and contractors are continuing to learn about how to most effectively sample surface

water and groundwater to accurately capture potential PFAS exposures. One especially challenging

aspect to the Project 1007 investigation and remediation effort is the presence of PFAS-containing

foams on surface water, which can be significantly enriched in PFAS compared to the surrounding water.

Another challenge with surface water sampling for PFAS stems from the fact that many PFAS prefer to

concentrate at the very surface of the water, in what is called the “air-surface microlayer.” Collecting

samples only below the surface would likely underestimate the true PFAS concentration in the

waterbody. Sampling only the air-surface microlayer may not be representative of an overall PFAS

surface water exposure in some settings, but in other settings (like considering potential exposure to an

animal drinking from the surface of a waterbody) knowing the concentration of PFAS in the air-surface

interface can be very informative. Additionally, there have been recent advances in passive samplers for

PFAS in surface water and advances in understanding of PFAS dynamics in bedrock formations and

during groundwater well sampling. In order to expand the available expertise to tackle challenges

associated with sampling strategies, MPCA has developed an ongoing collaboration with EPA’s ORD to

compare sampling methods for PFAS foam, assess environmental conditions that lead to PFAS

stratification in the water column, and evaluate passive monitoring well samplers for PFAS in

groundwater.

Minnesota’s PFAS Blueprint • February 2021

Work status: ongoing

Leaders: MPCA Remediation Division. Partners: EPA Office of Research and Development.

Benefits: Technical assistance from EPA’s ORD team will benefit Minnesota by providing

comparative analysis of PFAS sampling methods and tools and a better understanding of the

potential for PFAS to stratify in surface water. Evaluating methods for sampling PFAS-containing

foam on surface water will provide consistency in comparison of analytical results from varying

environmental conditions where PFAS-containing foam exists.

Challenges: Standardizing sampling protocols and tools is challenging in heterogeneous

environmental conditions with varied hydrologic and geologic settings. Thought will be needed to

clearly define the goal of the sampling strategy – for example, the goal could be to accurately

capture the bulk water concentration for a surface water stream or to capture a likely exposure

scenario for wildlife using the waterbody for drinking.

Resources: Investigating and remediating the Project 1007 Corridor is a cost and time-intensive

process – through fiscal year 2021, $4 million will have been spent on this effort and work will

continue thereafter. The additional collaboration and coordination with EPA’s scientists in the Office

of Research and Development will not require resources and may reduce the amount of funds spent

on tackling these issues with MPCA’s contractors and staff alone.

Revising PFAS Analytical Guidance Document

The purpose of the PFAS Analytical Guidance Document

is to provide guidance to MPCA programs. The

criteria described within the document are considered minimum standards (the laboratory may use

stricter criteria) that should be met when analyzing and reporting sample results to the MPCA. The

guidance supports MPCA staff in reviewing the data collected and reported by contractors and regulated

parties. Information included in the document includes specifications on how PFAS samples should be

collected and stored for various media, how instruments should be calibrated, and which PFAS should

be measured at what minimum reporting levels. This document is regularly revised to incorporate the

rapid evolution of knowledge regarding PFAS contaminant analysis – revisions are currently underway.

Work status: ongoing

Leader: MPCA Environmental Data Quality Section.

Benefits: This document helps ensure that data are collected in an accurate and consistent manner,

whether for research purposes or for regulatory purposes. This document is also a helpful reference

for contract labs and private entities around the state looking to produce high-quality PFAS data that

would be acceptable to MPCA or MDH. Though the MPCA Environmental Data Quality Unit

encourages labs to reach out with phone calls or questions about the complications of PFAS analysis,

having the basic quality assurance information in a short reference guide is a helpful tool.

Challenges: The analytical methods used to measure PFAS and the best practices for collecting PFAS

samples are constantly evolving – there is not always immediate consensus on best practices.

Additionally, as one of the purposes of this document is to ensure consistency of PFAS results

measured in different laboratories, this document states what is acceptable to the MPCA, not

necessarily all that is possible. For example, even if one lab can detect to new, lower detection

limits, if this technology is not yet available to multiple facilities, the lower detection limits may not

be included in the guidance document. This desire to balance high-quality data incorporating the

most recent improvements with accessibility of methods makes updating the guidance document

challenging.

MPCA. (2020). Guidance for Perfluorochemicals Analysis. Retrieved from: https://www.pca.state.mn.us/data/mpca-quality-

system

Minnesota’s PFAS Blueprint • February 2021

Resources: This effort requires MPCA staff time revisit the document approximately every year to

determine if updates are needed.

Considering additional PFAS methods to add to the MDH lab accreditation program

The MNELAP was established in 1989 to ensure the accredited laboratory is capable of performing

analytical measurements and to hold accredited labs accountable to standards that support the

generation of defensible and accurate data. MNELAP offers accreditations to accommodate the needs of

many state and federal environmental programs including testing required by the Clean Water Act

(CWA), Resource Conservation and Recovery Act (RCRA), Underground Storage Tank Program, and the

Safe Drinking Water Act (SDWA). Laboratories apply each year to MNELAP for accreditation, and

MNELAP tracks proficiency of labs, works with approved third-party assessors to conduct on-site

assessments every two years, and holds enforcement authorities should a lab deviate from method or

quality assurance procedures.

In the early days of PFAS investigations in Minnesota, there were a very limited number of methods

available to measure PFAS in various media, and there were no standardized EPA-approved methods.

For this reason, MPCA worked with the MNELAP to use the guidance document on PFAS analysis

published by MPCA (described in the section above) for accrediting labs in lieu of published analytical

PFAS methods. The MPCA Environmental Data Quality unit, which is responsible for maintaining the

PFAS analytical guidance document, is working closely with MNELAP and other programs within MPCA

to consider which PFAS methods should be made available for the purpose of accrediting labs in the

future.

Work status: ongoing

Leader: MPCA Environmental Data Quality. Partner: Minnesota Department of Health

Environmental Laboratory Accreditation Program (MNELAP).

Benefits: Adding PFAS methods to the list of fields of testing available for accreditation will help

ensure consistency from environmental laboratories to report defensible data from validated and

standardized methods.

Challenges: Though PFAS methods are becoming available from EPA and other sources, there may

still be PFAS analytes of concern in matrices without standardized methods available at this time.

The MPCA Environmental Data Quality program will need to consider if MPCA programs require that

labs continue to be accredited based on the MPCA guidance document for PFAS analysis rather than

a standardized method in some cases. Additionally, some outreach to labs may be needed to help

explain any changes to the accreditation process for PFAS analysis.

Resources: Staff time in the MNELAP program and MPCA programs will be needed to review

analytes, help communicate changes to labs, and potentially assist with onsite audits for new

methods. Additional funding maybe required if the current accreditation database needs to be

upgraded, modified, or improved to meet the needs of the laboratories and clients.

Gaps and opportunities

Researchers and regulators in Minnesota and across the nation are struggling with the many remaining

gaps in measuring PFAS. With potentially thousands of PFAS occurring in the environment, the vast

majority of PFAS are not currently included in widely available analytical methods. These undetectable

EPA (2020). PFAS Analytical Methods Development and Sampling Research. Retrieved from: https://www.epa.gov/water-

research/pfas-analytical-methods-development-and-sampling-

research#:~:text=Standard%20Analytical%20Methods%20%20%20%20Media%20,for%20non-

drinking%20...%20%209%20more%20rows%20

Minnesota’s PFAS Blueprint • February 2021

PFAS may pose a concern for human health, ecosystem health, or both. Compounding the problem, it is

difficult to know which new PFAS should be targeted for addition to standard analytical methods

because it is not known which PFAS we should expect to occur in the environment – companies are not

required to report the PFAS they produce in all cases, and often if the information is reported to EPA, it

is protected as “confidential business information” and cannot be released. Though this is an immense

challenge, there are a number of opportunities for progress. Increased availability and accessibility of

non-targeted analytical methods would help prioritize additional specific method development and

greatly improve the understanding of the entire landscape of PFAS mixtures present in environmental

media. Increasing Minnesota’s capacity to conduct non-targeted analysis could be possible by

implementing creative financing options for gaining access to instruments, like lease-to-own structures,

and by employing post-docs or funding for graduate students to work on projects with set durations.

Additionally, access to data like environmental release information for PFAS, importation data for PFAS,

and labeling of PFAS in commercial and industrial products would greatly improve the understanding of

which PFAS are likely to occur and where. This information would help prioritize the development of

new analytical methods.

There are new methods available that may be helpful in answering questions in site investigation or

product screening contexts when traditional analytical methods are either not available or not the most

efficient tool. PFAS analysis using traditional analytical methods is expensive -- at a cost of $300-$400

per sample, costs for investigating PFAS can quickly become prohibitive. Having access to a screening

level method may be able to help prioritize sites for further investigation. Additionally, if the goal of

sampling is not to determine which PFAS are present but to understand the total level of PFAS, less

expensive analytical methods for measuring TOF could reduce the burden of conducting PFAS analysis

and increase the likelihood of identifying new PFAS contamination sites. Another new tool to identify

whether PFAS is present in the surface of solids is called PIGE analysis. Gaining access to this tool could

help identify PFAS-containing products, potentially increasing the ability for MPCA target source

reduction efforts in waste streams and making it easier to enforce potential future regulations on PFAS-

containing products. Overall, expanding the toolbox of PFAS methods available would be useful for

many PFAS management efforts.

Ensure capacity to meet the demand for non-targeted PFAS analytical approaches

Currently, the PHL has skilled staff and instrumentation needed to conduct non-targeted analysis for

PFAS, but staff time and scheduling time on the required instrument are limited. The goal of this project

proposal would be to continue to develop and implement suspect screening and non-target approaches

for PFAS in environmental samples and expand the availability to conduct non-targeted analysis as

requested by MPCA or MDH programs. Non-targeted analysis can help identify PFAS that are present in

a sample that otherwise would not be detected using targeted methods. While non-targeted analysis

does not allow for quantifying PFAS, the signal responses can provide a qualitative estimate of which are

likely to be the most abundant. This work could support investigations into sites where unknown PFAS

may be present. Collaborations with partners at Minnesota Universities may be beneficial.

Work status: under consideration – would be paired with additional PFAS research and site

investigations

Leader: MDH Public Health Lab. Partners: Partnering academic labs (if applicable).

Benefits: Studies have shown that targeted analytical methods for PFAS frequently capture only a

small percentage of the total PFAS present.

Having the ability to run non-targeted analyses would

allow site investigators and others at MPCA and MDH gain a more complete picture of the PFAS

McDonough, C., Guelfo, J.L., & Higgins, C.P. (2018). Measuring Total PFAS in Water: The Tradeoff between Selectivity and

Inclusivity. Current Opinion in Environmental Science and Health, 7, 13-18. doi: 10.1016/j.coesh.2018.08.005.

Minnesota’s PFAS Blueprint • February 2021

present in various samples. Suspect screening allows for the qualitative analysis of hundreds of

known precursor PFAS for which analytical standards may not exist. While unequivocal identification

requires analytical standards, probable identifications can be made and supported by additional

chemical or contextual evidence. Additionally, non-targeted analysis can facilitate the discovery of

unknown PFAS, as was recently done in New Jersey.

Challenges: Suspect screening and non-target analysis requires highly technical and laborious data

processing. Instrument availability is also a potential issue; currently Minnesota labs have two

instruments capable of suspect screening and non-target analysis, but they are frequently used or

dedicated for other projects.

Resources: Expanding access to non-targeted analysis for PFAS in Minnesota public labs may require

purchasing or renting of additional instruments and hiring of additional staff with expertise in non-

targeted methods for PFAS.

Ensure capacity to meet the demand for alternative PFAS methods

This proposal is to research and possibly adopt screening methods for PFAS in Minnesota public labs.

Options for PFAS screening include TOF and PIGE analysis. These methods do not determine exactly

which PFAS are present in a sample. However, they could be used for various applications including:

determining the percentage of PFAS detected in a given sample using standard analytical methods,

estimating the total PFAS in a given product, or estimating the total PFAS in a sample as a mechanism to

prioritize investigations.

Work status: under consideration – would be paired with additional PFAS research and site

investigations

Leader: MDH Public Health Lab.

Benefits: With potentially thousands of PFAS in the environment and used in commerce, measuring

the tens of PFAS with standard analytical methods available only captures a piece of the entire PFAS

landscape. Additionally, with novel PFAS being developed constantly, standard analytical methods

are highly unlikely to capture PFAS being produced today. Having the ability to run screening PFAS

analysis in MPCA and MDH labs would help staff in various program activities. For example,

screening PFAS methods that are faster and cheaper than traditional analytical methods could help

screen for PFAS concentrations in surface water foams, prioritize sites for PFAS investigation, and

quickly track the movement of PFAS spills or plumes.

Challenges: Currently, Minnesota public labs do not have the equipment or staff availability to

investigate new screening methods, and there are limited staff available with expertise in PFAS.

Additionally, the preferred screening method for PFAS will likely depend on the application where it

is needed. Collaboration between the lab and program staff, along with possible collaborations with

academic labs, may be helpful.

Resources: Though researching possible screening methods for PFAS would not require significant

additional resources, implementing new screening PFAS methods would likely require additional

instrumentation, additional trained staff, and possibly additional reagents or other equipment.

Washington, J., Rosal, C.G., McCord, J.P., Strynar, M.J., Lindstrom, A.B., Bergman, E.L., Goodrow, S.M., Tadesse, H.K., Pilant,

A.N., Washington, B.J., David, M.J., Stuart, B.G., & Jenkins, T.M. (2020). Non-targeted mass-spectral detection of

chloroperfluoropolyether carboxylates in New Jersey soils. Science, 368, (6495), 1103-1107. Doi: 10.1126/science.aba7127

Minnesota’s PFAS Blueprint • February 2021

Overview of intersectional issues

 Quantifying PFAS toxicity: Understanding the potential health impacts of PFAS exposure is key

in ensuring exposure stays below “safe” thresholds and communicating with the public. Health-

based guidance values, however, have been revised to lower and lower concentrations as

information about some PFAS emerges. It can be challenging to develop analytical methods with

detection limits low enough to detect below health-based standards in most media.

 Managing PFAS in waste: Landfill leachate, effluent and biosolids from wastewater treatment

plants, and contact water from composting facilities all contain PFAS stemming from industrial

and commercial uses of PFAS-containing products. Developing methods capable of measuring

PFAS in complex matrices like landfill leachate is challenging, and often these methods will have

higher detection limits than those designed for “clean” matrices like drinking water.

 Protecting Minnesota wildlife: There is limited data on PFAS in various animal tissues.

Developing methods in Minnesota public labs capable of measuring multiple PFAS in samples

like fish tissue, deer tissue, and other biological specimens would be challenging and expensive.

 Preventing PFAS Pollution: Phase-outs or bans of certain PFAS uses in commercial or industrial

products would likely require some level of enforcement. The availability of screening methods

like PIGE would help identify products with PFAS in surface coatings. Screening methods like TOF

could help enforce PFAS bans in liquids.

Minnesota’s PFAS Blueprint • February 2021

Background

 Risk assessments are needed to ensure that the regulations or interventions controlling levels of

contaminants in water, soil, air, or other media are protective of the community’s health.

 Many PFAS occurring in environmental media do not have enough toxicity data to conduct risk

assessments – EPA and other international regulators have allowed persistent compounds like PFAS

into commerce without first requiring chemical producers to conduct and report sufficient toxicity

testing or even publicly reveal the chemical structure.

 Despite challenging data limitations, MDH developed health-based values for five PFAS (PFOA, PFOS,

PFHxS, PFBA, and Perfluorobutane sulfonate [PFBS]) and is currently reviewing a sixth, PFHxA.

 Existing risk assessments for PFAS have indicated they have many toxic effects, impacting multiple

organ systems. Toxic effects can occur during sensitive life stages like pregnancy and early-life

development. These effects have been observed in laboratory-based animal studies and

epidemiological studies conducted in exposed communities.

 Health-based values derived by MDH for drinking water assessments are also used by MPCA to develop

risk assessments for other media, such as surface water, fish tissue, and soils.

 There are many challenges to conducting additional risk assessments for PFAS.

 Many PFAS do not have widely available analytical methods to quantify their concentrations in

water, soil, sediment, or air.

 Most PFAS have significant data gaps in toxicological information that preclude the derivation of

risk-based values.

 The scientific literature regarding PFAS toxicity and occurrence is evolving rapidly; MDH is

conducting ongoing literature searches to identify if new data warrant revising existing risk

assessments. This is a significant effort.

What is Minnesota doing now?

 MDH continues to revise the existing PFAS toxicity assessments as new information becomes available.

 MDH is also evaluating exposure and toxicity data availability for new PFAS nominated through the

Contaminants of Emerging Concern (CEC) Initiative process.

 MDH has established formal collaborations with scientists from EPA’s Office of Research and

Development to identify how New Approach Methodologies (NAMs) could potentially advance our

understanding of PFAS risks to humans.

 Collaboration includes developing alternative risk assessment methodologies and testing these

methods to see if they are useful in providing risk context for data-poor PFAS that may be

occurring in Minnesota.

 NAMs can be used to prioritize PFAS for review and to conduct screening-level toxicity or

exposure assessment.

 Staff from Minnesota continue to collaborate with risk assessors in other states through the Great

Lakes PFAS Taskforce and other inter-state information sharing organizations to leverage each other’s

work on quantifying PFAS risks to humans.

Summary

Quantifying PFAS risks to human health

Minnesota’s PFAS Blueprint • February 2021

What are remaining gaps and opportunities for action?

 Gap: PFAS are found in air. There are currently no health-based air guidance values from federal

agencies and a limited number from state sources. Inhalation-based PFAS studies are limited; the

absorption, distribution, metabolism, and elimination of volatile PFAS are poorly understood.

 Opportunity: MDH could conduct systematic literature reviews every six months to compile data

relevant to PFAS inhalation routes and determine if inhalation risk assessments are possible with

the remaining data gaps.

 Gap: Repeat-dose animal studies for most PFAS are not available. Similarly, there are not sufficient

exposure data for most PFAS to understand the likelihood of exposure from various routes, such as

through drinking water, fish, other food, products, or air.

 Opportunity: New authorities to request data from entities using or producing PFAS could help fill

gaps in exposure and toxicity information. These new authorities would require legislative action.

 Opportunity: Continuing to partner with multiple teams of scientists in EPA’s Office of Research

and Development could help MDH capitalize on new research projects to understand PFAS toxicity

and exposure.

 Gap: Though previous studies measured PFAS levels in the blood of East Metro residents exposed

through drinking water, MDH has not conducted an epidemiological study aimed at understanding

how PFAS exposure relates to adverse health outcomes.

 Opportunity: Funding for MDH to conduct an epidemiological-based health study in the East

Metro.

How does this work benefit human health and the environment?

 Understanding the thresholds at which adverse effects from PFAS exposure are unlikely to occur allows

for health-protective guidance and regulation. This guidance or regulation can then be implemented

to ensure that interventions take place if there are potential health risks to the community.

 Minnesota has in-house expertise to develop risk-based values – this allows agencies to develop

guidance for contaminants that are specifically relevant in our state and not to wait for the many years

that it often takes for EPA to publish new risk assessments.

 Given the lack of toxicity and exposure data for nearly all PFAS found in the environment, exploring

new approach methodologies for contextualizing PFAS risk will help prioritize PFAS for additional

research and potentially allow for development screening-level toxicity assessment.

How does this work benefit Minnesota’s economy?

 Preventing adverse physical health outcomes associated with PFAS exposure and preventing negative

mental health outcomes associated with concern over exposure to these compounds is financially

beneficial for families and individuals.

Minnesota’s PFAS Blueprint • February 2021

Background

Many environmental regulations are designed so that the concentration of chemicals in water, soil, air,

or other media are kept below levels deemed protective of the community’s health (though some

regulations take into consideration available technology, cost-benefit analysis, and other factors in

addition to purely health-based risk assessments). Calculating health-protective concentrations requires

a comprehensive synthesis of toxicity and exposure information, along with an accounting of what risks

may be associated with any data gaps that exist. In Minnesota, staff at MDH and MPCA develop risk

assessments used to develop health-protective environmental guidance and regulation.

Understanding the health and environmental risks of chemicals

Understanding the doses at which a chemical is unlikely to impact health is critical to determining safe

concentrations of the contaminant in various media like water or soil in the environment. Risk

assessment is the process of understanding the negative health effects associated with exposure to

chemicals and identifying the levels that are unlikely to cause those negative effects. In order to

complete risk assessments, scientists compile and synthesize data describing a compound’s toxic effects,

the way the compound moves through the body, and the way and degree to which various communities

could be exposed. The goal of these assessments is to determine the dose threshold at which adverse

health effects from exposure to a compound are not likely to occur. Sometimes this dose is given the

shorthand term of “safe dose” or “reference dose.” Assessing toxicity is a technical process practiced by

a team of experienced toxicologists and other specialists.

When conducting risk assessments, scientists can consider the type of exposure (exposure from

breathing, ingesting, or absorbing through the skin), the duration of exposure (from “acute” studies

spanning a day to “chronic” studies spanning an entire lifetime), the timing of the exposure (for

example, exposure during pregnancy or during stages of early-life development), and the organ systems

that might be most sensitive to adverse effects (for example, the liver or the nervous system). In the

context of environmental exposures to toxicants, “safe doses” are calculated so that the most sensitive

organ systems and the most sensitive population groups are protected.

An entirely complete dataset for toxicity and exposure is rarely available for environmental

contaminants. It is not ethical to test the effects of a toxic compound on humans. Instead, risk assessors

often reference experiments on animals. These animal studies could be of various durations, including

“chronic” studies, meaning that the experiment lasts the majority of the laboratory animal’s expected

lifetime, or studies that are “multigenerational,” meaning that the laboratory animals are bred during

the experiment, and toxic effects are observed in the pregnant animals and in the new offspring through

maturity. These chronic and multi-generational studies can be important for identifying adverse health

effects that could emerge if there is prolonged exposure to an environmental contaminant over all

stages of life, including pregnancy and infancy. These effects could include reductions in fertility,

developmental effects, and cancer. In the PFAS family, some compounds have shown carcinogenic

effects (PFOA) and others have shown sensitive immunological effects in infants exposed during

gestation and early life (such as PFOS). Other sensitive effects for PFAS include thyroid and liver effects,

and effects on energy metabolism. Many PFAS have data gaps in some areas of concern – for example,

many PFAS do not have chronic or multigenerational studies available, or even shorter-duration studies

measuring effects in organ systems that have been shown to be sensitive. Risk assessors can account for

uncertainties associated with data gaps using established risk assessment tools like uncertainty factors.

For some PFAS, there are so many data gaps that risk assessors have limited ability to draw conclusions

about the amount of exposure that could cause adverse health outcomes over a lifetime. In these cases,

conducting traditional risk assessments is not possible.

Minnesota’s PFAS Blueprint • February 2021

Developing health-based guidance values

MDH has authority and ability to promulgate health-based guidance values for pollutants in

groundwater that may impact human health when consumed in drinking water (Minn. Stat. 103H.201).

Conducting new risk assessments and revising existing assessments in order to develop these values

requires significant time from experienced staff and the availability of toxicity and exposure data. Many

states do not employ risk assessors and toxicologists capable of quantifying toxicity values for

contaminants of emerging concern, and instead rely on federal agencies or others to derive health-

protective values. In Minnesota, we have the capacity to derive toxicity values for oral and inhalation

routes of exposure, which can then be used in many contexts including the issuing of guidance or

development of regulatory values. In fact, Minnesota has derived over 100 health-based values for

potential contaminants of concern, including five PFAS, and regularly updates those values to reflect the

most recent research. This expertise allows Minnesota agencies to have risk-based values available for

contaminants that are specifically relevant in our state and not to wait for the many years that it often

takes EPA to publish new risk assessments.

Understanding the potential effects of prolonged exposure to an environmental toxicant often requires

data from animal studies. Even when performing these studies in laboratory animals with short

lifespans, like mice and rats, experiments frequently take two years of dosing and observation. Costs for

assessing the chronic or multi-generational toxicity can exceed several million dollars per chemical. Even

conducting shorter-duration studies (like sub-chronic studies), requires significant time and funding. For

most PFAS, important toxicity experiments have not been conducted or have been conducted but are

not publicly available. These gaps leave risk assessors with limited data to draw conclusions about the

amount of exposure that could cause adverse health outcomes over a lifetime.

Once MDH has determined the amount that is protective over a specified time period, an exposure

assessment is conducted to ensure that total exposure to the compound (from all routes) is unlikely to

exceed the protective level. In the context of drinking water consumption, the exposure assessment

estimates the amount of water a person drinks and the percentage of a person’s total exposure that

could be expected to come from drinking water.

MDH takes care to consider exposures in sensitive

life-stages (such as bottle-fed infants) and in population groups that may have elevated exposures. With

synthesized exposure data, it is possible to calculate the concentration of a contaminant in drinking

water that would keep total exposure within a range that is unlikely to result in adverse health effects.

These resulting “health-based” concentrations for groundwater used for drinking water are risk-based

values. They have different names depending on the process used to publish the results. A health based

value (HBV) is a guidance value that represents the amount of a chemical in drinking water that is

considered safe for people to drink over a specific time period. When HBVs promulgated through the

rule-making process, they become Health Risk Limits (HRLs). While both HBVs and HRLs are drinking

water guidance values – meaning that their publication or promulgation does not result in regulatory

action related to groundwater or finished drinking water – some programs, particularly at MPCA, use

these drinking water guidance values in regulatory contexts such as in remediating contaminated sites.

The “reference doses” used to calculate HRLs and HBVs are also useful to other programs assessing

potential risks from exposure in contexts other than groundwater used as drinking water. For example,

risk assessors in MPCA may use the toxicity assessment of a “reference dose” from MDH to derive

guidance values that are protective in scenarios where exposure is coming from recreating in surface

water or from children’s accidental ingestion of soil. The resulting risk-based values for these

MDH has authority under the Groundwater Protect Action, under Minn. Stat. 103H.201, to promulgate health risk limits

(HRLs) for substances in groundwater that are potential drinking water contaminants.

Minnesota’s PFAS Blueprint • February 2021

assessments are different than the corresponding HRL or HBV for the compound due to the differences

in exposure from various types of contaminated media.

What is known about PFAS toxicity

MDH has prioritized risk assessments for PFAS currently known to occur most frequently in Minnesota’s

drinking water and for those that are known to occur at sites with PFAS contamination, assuming

toxicity data are available. For the PFAS with toxicity data available and complete risk assessments,

toxicologists have identified a range of adverse effects associated with exposure. Those effects involve

multiple organ systems, including sensitive effects in developing immune systems in fetuses and infants.

The “reference doses” derived in the assessments for PFAS are protective of the most sensitive effects in

the most sensitive groups or life stages (such as infants or pregnant mothers). In many cases, human

epidemiological studies have confirmed the findings of adverse outcomes seen in animal studies and

identified additional correlations between PFAS exposure and other adverse outcomes including

increased incidences of ulcerative colitis, thyroid disease, testicular cancer, kidney cancer, and

pregnancy-induced hypertension. To date, there have been hundreds of studies of human health effects

and their association with PFAS exposure, including a large study of people living in the Mid-Ohio Valley

who had been exposed to PFOA.

The assessments for PFAS with health-based guidance values are

available on the MDH webpage.

Challenges to quantifying PFAS toxicity

There are many PFAS in the environment without the toxicity data required to assess if those

compounds exist in concentrations that may pose a risk to human health. There are over 5,000 known

PFAS structures by some estimates,

hundreds of which are currently used in commerce or industry in

the US The chains of carbon-fluorine bonds in PFAS make them extremely persistent in the environment

– in many cases environmental degradation is so slow that it is, for practical purposes, non-existent. This

persistence is often paired with a high degree of mobility in water, so that PFAS can spread rapidly

through and between aquifers and surface water. Though some PFAS follow common patterns in

absorption, distribution, and elimination from the body, there are exceptions to the observed trends.

For example, though longer-chain PFAS tend to stay in the body longer (have longer biological half-lives),

there are exceptions to this trend like PFHxS, which has a longer biological half-life than PFOS despite

having six carbons on its per-fluorinated chain compared to eight carbons for PFOS. This diversity in

PFAS traits makes it difficult to make broad conclusions about the toxicity of PFAS based on chemical

structure.

C8 Science Panel (2020). http://www.c8sciencepanel.org/

MPCA. (n.d.). Human Health-Based Water Guidance Table. Retrieved from:

https://www.health.state.mn.us/communities/environment/risk/guidance/gw/table.html

EPA (2020). Chemistry Dashboard, PFAS Master List. Retrieved from:

https://comptox.epa.gov/dashboard/chemical_lists/pfasmaster

Minnesota’s PFAS Blueprint • February 2021

Figure 2. Schematic diagram of PFAS risk assessment and method availability.

A key barrier to understanding the toxicity of various PFAS is that US regulations do not require toxicity

research before compounds enter commerce. Approval of chemical use occurs at the EPA through the

Toxic Substances Control Act (TSCA) program. TSCA requires manufacturers to submit only basic

information on new products and product chemistries before the EPA approves them for use and does

not stipulate that chemical companies conduct toxicity experiments before compounds are introduced

into commerce. For this reason, even EPA, the entity which collects and reviews toxicity information

from chemical manufacturers in the TSCA program, states that they do not have the data required to

conduct risk assessments for most PFAS found in water.

When these compounds appear in drinking

water, surface water, air, and soils, risk assessors have limited ability to determine if observed

concentrations potentially pose health risks. Toxicological studies by academic or government

researchers tend to occur only after the compounds are found in the environment. However, many PFAS

do not even have widely available methods to measure their concentrations in water or other media.

The identity of all PFAS used in commerce and the amounts entering the environment annually is

currently unknown. Figure 2 illustrates how the number of PFAS in the environment greatly outnumber

the PFAS with laboratory analytical methods available for measuring them and the PFAS with health-

based guidance available.

Past and ongoing efforts

The following section describes the completed and ongoing work related to quantifying the toxicity of

PFAS. Minnesota agencies have been leaders in PFAS risk assessment since 3M contamination of some

of Minnesota’s groundwater and drinking water was discovered in 2002. MDH staff have extensive

toxicological expertise on PFAS, and MDH was the first in the nation to derive health-based values for

two PFAS: PFOA and PFOS.

Since the early days of concerns about PFAS in drinking water and the environment, the science

regarding PFAS toxicity has rapidly evolved. Staff at MDH have gone on to conduct risk assessments for

three additional PFAS (PFHxS, PFBA, PFBS) in drinking water and continue to update their PFAS risk

assessments as new data becomes available.

EPA (2020). Announcement of Preliminary Regulatory Determinations for Contaminants on the Fourth Drinking Water

Contaminant Candidate List. Retrieved from: https://www.federalregister.gov/documents/2020/03/10/2020-

04145/announcement-of-preliminary-regulatory-determinations-for-contaminants-on-the-fourth-drinking-water

Available analytical methods and health-based guidance

Available analytical methods, but no health-based

guidance

No analytical methods, no health-based

guidance

Minnesota’s PFAS Blueprint • February 2021

Established and revised HRLs and HBVs for five PFAS

MPCA requested soil and groundwater

guidance values from MDH in 2002 to

assist with investigations in the Superfund

program, nearly 20 years ago. Detections

of PFAS by the 3M Company at their

Cottage Grove facility resulted in MPCA

requesting that MDH develop Health

Based Values (HBVs) for PFOA and PFOS

to assist the MPCA in their site

investigations. The first PFAS HBVs in

2002 were chronic HBVs of 7 µg/L for

PFOA and 1 µg/L for PFOS, which were

based on the limited toxicity information

available at the time. New laboratory

methods became available in 2006 that

expanded the list of chemicals that could

be identified in water to include five more PFAS: PFBA, PFBS, PFPeA, PFHxA and PFHxS. In the absence of

toxicity information, the HBVs for PFOA and PFOS were at times used as surrogates for PFBA and PFHxS,

the two additional PFAS of most concern.

Revised chronic HBVs for PFOA and PFOS were derived in 2007 and promulgated as HRLs in 2009. As

new toxicity information, population-wide exposure, and half-life information continued to accumulate,

MDH derived new subchronic and chronic values for PFBA, PFBS, and PFHxS. In order to keep using the

best available science for the two longest-established PFAS HBVs, MDH conducted re-evaluations of

PFOA and PFOS following the release of EPA’s Health Advisories for PFOA and PFOS in 2016. The revised

value for PFOA was promulgated as a HRL in 2018. Figure 3 illustrates how PFAS health guidance has

evolved over time.

Since 2008, MDH has developed guidance for over 100 chemicals, five of which are in the PFAS family.

To maintain accurate and current guidance values, all chemical guidance derived since 2008 is re-

evaluated on an approximately five-year schedule. This process identifies whether existing health-based

guidance values are up to date with the current available scientific information and current MDH

methodology. A chemical may be selected for re-evaluation based on a variety of factors, including the

following: substantive new toxicological information, programmatic need for an updated value

(including selection of the chemical for rulemaking), and/or an update to MDH risk assessment

methodology. A distinct part of this effort is identifying and evaluating high quality, well-designed

published studies that have the potential to change the established water guidance values. PFAS water

guidance values established by MDH are part of the overall effort MDH maintains to keep guidance

values up to date.

As part of the re-evaluation of PFAS, MDH developed a model to better understand how maternal PFAS

levels impact infant exposures and used this model to help set the water guidance value at a level

protective of all segments of the population, including breastfed infants. Numerous other states also

used this open access, publicly available peer-reviewed model to help them set water guidance values

for PFAS. Notably, the EPA’s health assessments for PFOA and PFOS do not directly consider the

additional exposure to infants from exposure to their mother during gestation and breast-feeding. It is

possible that when EPA revises their guidance for PFOA and PFOS, they will consider relying on MDH’s

model or a similar model to ensure protection of the most sensitive groups.

Figure 3. How PFAS guidance has been revised to reflect

new findings in the toxicological literature.

Minnesota’s PFAS Blueprint • February 2021

Work status: ongoing

Leader: Health Risk Assessment Unit, Environmental Health Division, MDH. Partners: MPCA

Remediation, MPCA Environmental Analysis and Outcomes.

Benefits: MDH was the first governmental agency in the nation to develop health-based guidance

values for per- and polyfluoroalkyl substances (PFAS) in drinking water -- the EPA did not issue

provisional drinking water advisories for PFOA and PFOS until 2009, seven years after MDH derived

the initial values for PFOA and PFOS. MDH’s health-based values provide risk-based and public

health protective guidance to Minnesotans impacted by PFAS in their drinking water, giving

Minnesotans vital information regarding when to act on PFAS contamination in water supplies. In

collaboration with MDH, municipalities and water utilities across Minnesota use the PFAS HBVs and

HRLs to understand the impact to their water resources and when to consider treatment. MPCA

additionally uses HBVs and HRLs to determine where bottled water and installation of water

treatment should be provided to impacted residents on private wells. The toxicity values derived as

part of MDH’s guidance development are used by MPCA to develop values for other media with

different exposure scenarios than drinking water, such as soil and surface water.

Challenges: As public awareness and concern regarding PFAS has increased, so has research into

some of the most commonly monitored PFAS, like PFOA and PFOS. Keeping up with the many

journal articles published each month to assess if revisions to HRLs or HBVs are warranted requires

significant effort. PFAS are high priority chemicals for review in the Health Risk Assessment Unit and

it is anticipated that further evaluations of public health protective water guidance values for PFAS

will be needed over the next several decades.

Resources: Since 2015, MDH has completed approximately 30 re-evaluations for chemicals with

existing guidance. For PFAS, keeping the guidance for PFOS and PFOA up to date has been a high

priority over the past five years. The development of HBVs and HRLs requires sufficient available

data, and highly trained exposure scientists, risk assessors, and toxicologists. Establishing new

guidance or re-evaluating PFAS guidance can require up to two years for each PFAS. Due to the ever-

increasing body of research on PFAS, the future anticipated resource needs are considerable as

revision of existing of values and creation of new guidance values are undertaken. The promulgation

of the HBVs into HRLs requires legal expertise and management support. Responding to public

comments during promulgation can also be time intensive. Access to the scientific publications, as

well as establishing and maintaining strong links to other state and federal experts are also required.

A new dedicated PFAS toxicologist position would be helpful in continuing to advance this work.

Evaluating additional PFAS for possible new health values under the CEC Initiative

Through this initiative, MDH collaborates with partners and the public to identify contaminants of

interest, investigate the health and exposure potential of contaminants of emerging concern (CEC) in

water, and inform partners and the public of appropriate actions for pollution prevention and exposure

reduction. The CEC Initiative supports the Clean Water Fund mission to protect drinking water sources

and the MDH mission to protect, maintain, and improve the health of all Minnesotans. For the fiscal

year 2021 work plan, the CEC Initiative received nominations for 24 contaminants to be reviewed and

considered for a screening level evaluation of toxicity and exposure potential and then a potential in-

depth toxicological review and guidance development. Fourteen of these nominations were for PFAS,

underlining the importance of PFAS to MDH partners and stakeholders.

MPCA. (n.d.). Contaminants of Emerging Concern. Retrieved from:

https://www.health.state.mn.us/communities/environment/risk/guidance/dwec/index.html#cecnom

Minnesota’s PFAS Blueprint • February 2021

Work status: ongoing

Leader: Health Risk Assessment Unit, Environmental Health Division, MDH. Partners: Minnesotans,

local governments, non-profit organizations, state agencies, professional water resource

organizations, the University of Minnesota

Benefits: MDH’s CEC Initiative is well established and positioned to respond to citizen, state agency,

or other stakeholder needs for PFAS health-based water guidance value development. The diverse

stakeholders of the CEC Initiative provide more comprehensive perspectives regarding PFAS (and

other chemical) needs in responding to water contaminants found in surface water and

groundwater sources. Research, evaluation, and outreach activities around PFAS has been

conducted. Developing PFAS water guidance values is a key role of the State’s response to PFAS

contamination.

Challenges: Evaluating all PFAS scientific studies as they are published is extremely difficult due to

the volume of new research published on a wide variety of PFAS topics. Despite this immense

volume of publications, key data gaps regarding exposure and toxicity potential persist for many

PFAS. MDH has been a leader in developing PFAS water guidance values, and yet to date it only has

water guidance values for five PFAS. An additional water guidance value for PFHxA (nominated

through the CEC Initiative) is currently being developed.

Resources: The development of water guidance values for chemicals is a staff-time intensive

endeavor. The resources needed are highly trained exposure scientists, risk assessors, and

toxicologists to evaluate new and existing toxicity and exposure data in order to synthesize an

accurate picture of the risks to the general population and the potency of the chemical in question.

Only then can MDH arrive at a health protective guidance value that is appropriate for all (CWF) is

slated to sunset in 2034, and additional funding would be needed to continue this program after

2034.

Gaps and opportunities

With potentially thousands of PFAS in the environment, there are many gaps remaining in our

understanding of PFAS toxicity, exposure, and use. Chemicals are registered for use in commerce and

industry at the Federal level, under the TSCA. The TSCA program is run by the EPA. Though there were

some changes to TSCA made to tighten chemical regulations so that persistent, bioaccumulative, and

toxic substances have more controls and limitations on their uses, there are still very limited data

released on new PFAS being registered and PFAS already in use. There could be additional changes to

rules under the TSCA to require chronic and multi-generational toxicity studies for persistent

compounds before these compounds are allowed in commerce, but these rule changes fall under the

federal regulatory authority of the EPA. MPCA and MDH have provided formal comments on federal

rulemakings in the past and will have opportunities to continue advocating for health-protective

evaluations of PFAS under TSCA and other federal programs in the future. At the state level, a potential

mechanism to fill gaps in exposure and toxicity data left by the TSCA program is to provide Minnesota

agencies with the authority to request toxicity, product use, and release data from industrial and

commercial makers or users of PFAS. Though this proposed authority would not compel any entity to

conduct toxicity studies, it would help identify which PFAS are present in environmental media and may

result in confidential access to non-public toxicity studies. This proposal would require action by state

legislators.

Despite the significant ongoing effort to develop and review PFAS health-based guidance values,

continued opportunities remain to fill gaps in our understanding of toxicity from ingestion or inhalation

of PFAS. MDH could begin conducting regular literature reviews and compile evidence to determine if

Minnesota’s PFAS Blueprint • February 2021

inhalation risk assessments for various PFAS are possible given the current data landscape. These

periodic reviews would allow MDH to derive inhalation risk-based values for PFAS as soon as possible --

these risk-based values would be used by MPCA and others to determine if indoor air or ambient air

poses potential health risks. Additionally, MDH could continue the ongoing partnerships with

researchers in EPA’s ORD to capitalize on novel strategies to better contextualize PFAS risks. This work

includes projects aimed at predicting the metabolism and elimination of various PFAS in humans;

predicting the likelihood of PFAS exposure based on product use categories and probabilistic modeling;

and extrapolating data from high-throughput in vitro testing and computational, structure-based,

toxicity estimates. MDH is currently researching these cutting-edge risk assessment techniques and

could continue testing these new methodologies in the future. Finally, Minnesota has previously applied

to the CDC for funding to participate in a multi-state epidemiological study of PFAS health effects.

Though CDC did not choose to include the population living in the East Metro as part of their multi-state

study, MDH could conduct the proposed epidemiological study in the future if other funding is available.

This effort would involve recruiting participants for PFAS biomonitoring and tracking health outcomes in

these participants, including health indicators measured in blood and urine such as cholesterol levels

and tests of liver, immune, and thyroid function. These proposals are discussed in more detail below.

Establish authority to request data regarding contaminants of potential environmental

concern

Authority to allow the MPCA to request information about toxic compounds from companies that create

or use them would not prevent the discharge of these compounds into the environment, but would

likely help risk assessors gain the information they need to understand if environmental exposures to

these toxicants could cause adverse health outcomes. Data gaps with respect to PFAS limit the ability to

understand exposure levels in the environment, quantify toxic levels for humans or wildlife, and identify

parties responsible for contamination. MPCA would benefit from authority to request information from

entities on compounds in products when there is a concern over them. This authority would not require

any additional regular reporting by industries or entities, but it would allow MPCA to collect information

in a timely manner when concerns over a compound, including information that could help quantify the

exposure or toxicity of a specific PFAS. See the Remediating PFAS Contaminated Sites Issue Paper for

discussion of how this authority would also be relevant to identifying and investigating PFAS sites.

Work status: under consideration – requires legislative action

Leaders: MPCA Safer Chemicals Unit. Partners: MDH Health Risk Assessment Unit

Benefits: This authority could help MPCA identify PFAS actively used in Minnesota, which in turn

could prioritize research into the toxicity and exposure potential for these compounds. Additionally,

if there were an entity that had conducted non-public toxicity testing, this authority would also

allow MDH toxicologists to review the information.

Challenges: This authority would allow MPCA to request information from entities, but some crucial

data gaps like toxicity information may not filled; entities using or producing PFAS (or others) may

not have conducted toxicity testing on the relevant PFAS. This authority would help MPCA respond

to PFAS contamination, but it would not prevent entities from using or producing PFAS in the first

instance.

Resources: Enacting this authority would not require significant resources. It may save MPCA and

other agencies future efforts if they could acquire desired information directly from companies,

instead of having MPCA and other agencies recreate studies, techniques, etc.

Minnesota’s PFAS Blueprint • February 2021

Compile information on inhalation PFAS toxicity

There is opportunity to better understand if there are potential risks from inhaling PFAS in ambient or

indoor air. PFAS health-based guidance currently available from MDH considers PFAS exposure from

ingestion, not inhalation. This is largely because there is little understanding of how inhaling PFAS may

impact human health, and little understanding of how much exposure to various PFAS from ambient or

indoor air could be expected. Despite these significant data gaps, interest in PFAS exposure from air is

increasing, which is in turn resulting in additional toxicity and exposure studies being published.

In order to derive health-protective air guidance values, MDH must invest staff time and resources to

identify and evaluate high quality peer-reviewed studies that describe health effects from inhalation

exposure to PFAS. At this time, inhalation-based PFAS studies are very limited, as are air guidance values

from other federal and state sources. MDH plans to begin regularly reviewing the scientific literature

related to inhalation studies to identify if and when there is enough information available to conduct

inhalation risk assessments. In an effort to keep abreast with new PFAS inhalation literature leading to

the eventual development of air guidance, MDH toxicologists are conducting periodic (every six months)

literature searches for relevant studies. This effort will be going on concurrently with an MPCA research

project monitoring PFAS in air at various locations in the state (see the Understanding Risks from PFAS

Air Emissions Issue Paper). With this combined effort, it may be possible to quantify health-based air

values for PFAS occurring in Minnesota air.

Work status: planned

Leader: Environmental Impacts Analysis Unit, Environmental Health Division, MDH.

Benefits: Monitoring data from MPCA indicates that some PFAS are present in ambient air, and

additional PFAS monitoring in air is currently underway. Regularly reviewing the availability of PFAS

inhalation data in the scientific literature will allow MDH to develop of PFAS air guidance in a timely

manner.

Challenges: The greatest challenge to updating air guidance values is the dearth of inhalation

studies available in the literature. It may additionally be difficult to conduct systematic literature

reviews with consistent search terms as knowledge about novel PFAS structures evolve over time.

Working with experienced librarians to conduct these reviews would be beneficial for this project,

and careful record keeping of search strategies and review results will be paramount.

Resources: The development of air guidance values for chemicals is a time-intensive endeavor.

Highly trained toxicologists and risk assessors are needed to evaluate available toxicity and exposure

data, synthesize an accurate picture of the risks to the general population, and draw conclusions

about the potency of the chemical in question. Acquiring publications is costly because MDH does

not have access to all journals with potentially relevant publications. Library services are helpful

when conducting these types of systematic reviews because they can assist in designing search

queries, maintaining and organizing literature review data, and requesting publications via inter-

library loans when access is not immediately available. Only after a comprehensive literature review

and data analysis can MDH arrive at a health-protective air guidance value that is appropriate for all

Minnesotans, including sensitive subpopulations.

Research cutting-edge risk assessment techniques for data-poor PFAS

The availability of toxicity and exposure data, although increasing greatly over the past decade, is still a

limiting factor when conducting risk assessments for most PFAS. This problem of scarce data applies to

most (CECs beyond PFAS. To address this persistent problem of insufficient data and testing, MDH’s CEC

Initiative began work in 2011 on a special project called the Alternative Risk Assessment Methodology

(ARAM) Project. To date, two phases of the ARAM Project have been completed. The focus of phase one

was to identify candidate alternative risk assessment methods that could potentially provide some

Minnesota’s PFAS Blueprint • February 2021

level of risk context for contaminants with little or no toxicity information. The second phase conducted

basic testing of the methods selected as good candidates in phase one. Phase three is still in progress

and involves integrating the identified alternative methods into a decision tree and testing if the

decision tree is effective with a variety of contaminants and for a variety of health effects. Results from

this project indicate that the identified alternative methods work well for many chemicals, including

some of the shorter chain PFAS, but do not work well for bioaccumulative chemicals.

Another opportunity to advance understanding of PFAS toxicity could emerge through explorations of

novel toxicity review strategies currently under research and development at the EPA and elsewhere.

These new strategies are sometimes called “new approach methodologies” (NAMs). Scientists at MDH

are currently collaborating with EPA to develop NAMs relevant to Minnesota’s risk assessment process.

These NAMs could allow for prioritization of PFAS lacking key toxicological and exposure studies,

possibly resulting in characterizations of relative toxicity or relative likelihood for exposure among

various PFAS. Implementing NAMs could allow for consideration of additional PFAS, especially those

that are data-limited, but this effort would likely require additional resources in staff and funding.

Because these new strategies for addressing data-poor PFAS are cutting edge, applying any results in a

regulatory context would likely face challenges.

MDH has also been working collaboratively with EPA’s Center for Computational Toxicology and

Exposure on issues of toxicology and exposure for CECs. Part of this project will focus on using NAMs to

provide novel toxicity information in cell-based or computer-based testing environments. NAMs are

increasingly being used at the federal level to provide toxicity data in a faster way to bridge the data

gaps surrounding PFAS and other CECs. To date, NAMs have been used to prioritize chemicals for more

testing and to fill specific data gaps. However, the ongoing projects at MDH to develop and assess NAMs

will also evaluate the potential of these methods to provide risk context.

Work status: ongoing, additional work planned

Leader: Health Risk Assessment Unit, Environmental Health Division, MDH. Partners: EPA, Center for

Computational Toxicology.

Benefits: Creating new methods for use in risk assessment is a time-consuming task and requires

experienced scientists. Risk assessment as a process requires substantial amounts of data on both

toxicity and exposure. Alternative risk assessment methodologies hold great promise in speeding up

risk assessment, applying risk assessment science more broadly across a related group of chemicals,

and providing faster answers to our most important environmental questions.

While these two projects aimed at researching cutting-edge risk assessment techniques have

different scopes and objectives, a shared benefit of both projects is to provide risk context for

chemical exposures where traditional toxicology data are lacking or entirely absent. New

approaches must be used to address data-poor chemicals and PFAS, and these projects have the

potential to address this difficult problem.

Challenges: The challenges to interpreting and applying NAMs are considerable. These new

methods for contextualizing risk are inherently less precise due to a lack of full testing data on a

specific chemical compound. To date, these methods have primarily been used to prioritize the

completion of traditional risk assessments. Additionally, it may take considerable effort to convince

stakeholders that these novel risk assessment approaches are valid in various guidance or regulatory

contexts.

Resources: MDH will need staff time to continue working with the EPA on NAMs and their

application to PFAS risk assessments. Additional staff time will also be needed to see how PFAS can

be evaluated under the protocols of the ARAM Project.

Minnesota’s PFAS Blueprint • February 2021

Develop of an epidemiological study of residents exposed to PFAS through drinking water

In 2019, the CDC announced that they established cooperative agreements with seven partner states to

study the human health effects of exposures to PFAS.

Though Minnesota applied to have residents

from the East Metro Area be part of this study, other study locations in the US were selected as higher-

priority sites for investigation. Were MDH to have an alternative source of funding from the Legislature

or another source to conduct this study, the Agency could move forward with the originally proposed

epidemiological project. In this health study, MDH would work with the Washington County Department

of Public Health and Environment, local water system operators, other local government agencies, and

community groups to conduct outreach about the study and determine the best ways to share study

findings with the communities. Participants in the study would have PFAS levels measured in their blood

and urine and complete a survey to help reconstruct the participants’ exposure to PFAS in the past.

Then, health indicators measured in blood and urine such as cholesterol levels and tests of liver,

immune and thyroid function, along with health surveys, would track the participant’s health over time.

The study could include adults and children living in a home that is served by a PFAS impacted public

water system or a private well in the East Metro with detectible levels of PFAS.

Work status: under consideration, funding for this project would be needed

Leader: Environmental Surveillance and Assessment Section, Environmental Health Division, MDH.

Partners: Washington County Department of Public Health and Environment, local water system

operators, other local government agencies, and local community groups.

Benefits: Though animal toxicity studies are able to show how increased PFAS doses damage organ

systems under highly controlled conditions, these studies do not capture “real life” experiences of

humans with varied exposure levels, genetic susceptibilities, and lifestyles who may be affected by

environmental PFAS contamination. Studies that monitor PFAS levels in people and track health

outcomes over time, while more difficult to interpret in a risk assessment context than highly

controlled animal studies, provide important information for risk assessors and the impacted

community about how PFAS exposure may be impacting health.

Challenges: Conducting epidemiological studies has many challenges, including the logistics of

tracking the health outcomes from hundreds or thousands of participants over time, the technical

challenges of reconstructing exposure histories for participants, and the complexities of

communicating results to the impacted communities. It is possible that the results of the study

would not be conclusive, or would show that there is not an association between PFAS exposure and

the health outcomes tracked in the study. Conducting an epidemiological study would require

ongoing effort from a number of staff with a variety of areas of expertise over the course of many

years.

Resources: This effort would require approximately $8 million to $9 million in funding over the

course of five years.

Overview of intersectional issues

 Drinking water monitoring. Continuing to monitor for PFAS in drinking water will help prioritize

risk assessments for oral routes of exposure.

 Understanding air emissions. Expanding emission reporting and monitoring for PFAS in air will

help prioritize risk assessments for inhalation routes of exposure.

ATSDR. (2020). Per- and Polyfluoroalkyl Substances (PFAS) and Your Health. Retrieved from:

https://www.atsdr.cdc.gov/pfas/activities/studies.html

Minnesota’s PFAS Blueprint • February 2021

 Analytical methods. Measuring PFAS is expensive and time-intensive, and available methods

include only a subset of all PFAS that may be occurring in drinking water. Improved access to

and funding for non-targeted PFAS methods will help identify the complete landscape of PFAS

that may be occurring in drinking water, food, soil, or other relevant media. This will help

prioritize the development of new research and risk assessments.

 Pollution prevention. Reducing PFAS pollution at the source places the cost burden with

polluters rather than impacted parties, like drinking water utilities and the general public.

Though chemical registration occurs at the federal level, Minnesota could continue to enact

chemical use regulations for PFAS in the state (like the existing ban on uses of PFAS-containing

firefighting foam for training or testing purposes) and can continue to request that EPA require

substantial evidence that a substance is has very low toxicity if it is environmentally persistent

before it is allowed in industry or commerce.

Minnesota’s PFAS Blueprint • February 2021

Limiting PFAS exposure from drinking wate r

Background

 Minnesotans value safe and sufficient drinking water – when PFAS pollution is discovered, the first

questions from the community are frequently about the safety of their drinking water.

 Historic disposal of PFAS waste in the East Metro caused PFAS contamination of drinking water,

affecting over 174,000 Minnesotans. Temporary treatment systems were put in place to reduce PFAS

concentrations at impacted drinking water supplies -- efforts to remediate this contamination and

implement long-term drinking water supply plans are ongoing.

 Over time, decreases in detection limits for PFAS and improved understanding of PFAS toxicity have

contributed to the realization that many PFAS are ubiquitous in the environment and that some PFAS

are toxic at low doses.

 PFAS contamination in drinking water is not limited to waste sites associated with PFAS

manufacturers – drinking water impacts associated with use of PFAS-containing firefighting foam and

industrial activities have been discovered.

 Federal and state regulations align to protect water consumers. On the federal level, drinking water

monitoring and regulation falls under the SDWA.

 Though MDH has health-guidance values for five PFAS, there are currently no federal or state

drinking water standards for PFAS (i.e. Maximum contaminant level [MCLs]).The process for

federal rulemaking under SDWA has begun for PFOA and PFOS. Based on statutory deadlines in

SDWA, implementation of the proposed regulations would likely begin in 2025.

 Because there are no SDWA standards for PFAS, water systems may not be prioritized by the

Drinking Water Revolving Fund, which provides below-market-rate loans and grants for improving

or constructing treatment systems.

What is Minnesota doing now?

 MDH is prioritizing monitoring drinking water for PFAS – this effort fills gaps left by federally-required

monitoring for PFAS.

 MDH has planned and ongoing monitoring efforts in place that will cover at least 90% of people

served by community water systems by 2025. This effort is expected to require at least $10-15

million in resources for sampling, analysis, and follow-up action.

 MPCA and MDH work with property owners to test private wells in areas with known groundwater

PFAS contamination. Minnesota has collected over 20,000 samples from approximately 4,000

private wells and continues to receive requests for sampling.

 If concentrations of PFAS are found in drinking water that exceed MDH guidance values or the Health

Risk Index based on guidance values, MDH works with drinking water systems or private well owners on

appropriate next steps to reduce exposure.

 MDH continuously updates communication materials related to PFAS and drinking water to ensure

clear, complete, and up-to-date scientific information is included.

 MPCA has included PFAS in two rounds of monitoring in the Ambient Groundwater Well Network,

which provides an early warning system for PFAS migration into drinking water aquifers.

 MPCA and MDH are continuing to collaborate on potential drinking water impacts at known or likely

PFAS-contaminated sites.

Limiting PFAS exposure from drinking water

Summary

Minnesota’s PFAS Blueprint • February 2021

What are remaining gaps and opportunities for action?

 Gap: Reducing or eliminating ongoing sources of PFAS to waterbodies used as drinking water supplies

prevents the need for costly interventions like installing drinking water treatment systems for PFAS.

 Opportunity: MPCA can revise the Class 1 Water Quality Standards, which protect drinking water

sources from pollution, to include PFAS. These revisions would allow MPCA to set limits for

permittees discharging PFAS to waters used as a source for drinking water.

 Gap: The past and ongoing initiatives to monitor drinking water systems for PFAS will capture at least

90% of all community water consumers by 2025, but not all consumers.

 Opportunity: Expanding drinking water monitoring to all community water systems or monitoring

planned systems faster would require additional funding and lab capacity.

 Gap: Twenty-one percent of Minnesotans (~1.2 million people) get drinking water from a private well,

and currently private well monitoring only occurs near sites with known PFAS groundwater

contamination.

 Opportunity: As the Pilot PFAS Inventory Project (see the Remediation PFAS-Contaminated Sites

Issue Paper) and drinking water monitoring efforts identify new PFAS plumes, additional funding

may be needed to identify impacted private drinking water wells. Funding to include PFAS in

annual monitoring of the Ambient Groundwater Monitoring Network would additionally help

identify impacted or vulnerable aquifers.

 Gap: There are not currently drinking water standards (MCLs) for PFAS.

 Opportunity: MDH could evaluate options for managing risks from federally unregulated

contaminants, including PFAS. Federal rulemaking for PFAS drinking water standards has begun,

but would not be completed until 2025.

How does this work benefit human health and the environment?

 Monitoring for PFAS in drinking water has the direct benefit of promptly reducing PFAS exposure with

appropriate interventions if levels exceed those thresholds and reducing consumer anxiety about

exposure if levels are below health-based thresholds.

 Drinking water monitoring informs investigations into sources of PFAS, which can sometimes result in

cost recovery from parties responsible for the pollution.

 Reducing PFAS emissions to source waters for drinking water prevents harmful exposure to humans,

but also reduces exposure for fish and wildlife using those waterbodies.

How does this work benefit Minnesota’s economy?

 Well-developed regulations for PFAS ideally place the cost burden of PFAS controls with polluters

rather than imposing those costs on drinking water utilities and the general public.

 Safe and trusted drinking water is crucial to business development in Minnesota and growth in the

housing market.

 Preventing adverse physical health outcomes associated with PFAS exposure and preventing negative

mental health outcomes associated with concern over exposure is financially beneficial for families

and individuals

Background

Minnesotans value safe and sufficient drinking water – when new instances of pollution are discovered,

the first questions from the community are frequently about the safety of their drinking water. In many

cases, assessments demonstrate that contaminated drinking water is a meaningful source of exposure

to pollution. Because drinking water

is an avenue for potential exposure

to environmental pollutants and

because there is high public interest

in drinking water safety, there are a

network of federal and state laws in

place to ensure drinking water is

safe.

The structure for regulating public

drinking water systems in the US is

largely centralized at the EPA.

Under the SDWA, a federal law

enacted in 1972 and amended in

1986 and 1996, EPA has the

authority to enact drinking water

regulations that apply in every

state. Notably, EPA has not

regulated a new chemical under

SDWA since the 1996 Amendments

to the law were passed by Congress

-- these amendments included a

mandatory consideration of costs

and benefits before a rule could be promulgated. The federal rules under SDWA for public drinking

water systems require monitoring for regulated contaminants at specified intervals. However, SDWA

also requires that a subset of all water systems monitor for up to 30 unregulated contaminants every

five years. The data gathered in this unregulated contaminant monitoring program provides information

used to determine if new drinking water regulations are needed.

These federal drinking water regulations do not apply to all drinking water consumed in Minnesota.

Many federal drinking water standards apply only to “community” and “non-transient non-community”

drinking water supplies, which includes water distributed by systems like municipalities, senior living

facilities, apartment buildings, and manufactured home parks, but does not include water from

“transient non-community” systems (like some campgrounds, rest areas, and resorts). Figure 4

illustrates the different regulatory categories of drinking water systems and who they serve. Federal

regulations under SDWA also do not apply to private wells – there is no mandatory testing of private

wells and there are no enforceable limits for contaminants in private drinking water wells. Most

Minnesotans receive their drinking water through public water systems, but approximately 21% of

Minnesotans (about 1.2 million people) obtain drinking water from private wells.

Figure 4. Categories of public water systems.

Some states have the authority under state law to enact additional drinking water regulations or

protections that can help fill gaps in regulations set by the EPA. Minnesota does not currently have clear

regulatory authority to enact state drinking water regulations (MCLs), but does have the ability to fill

other gaps in federal

drinking water

regulatory authority. For

example, there is a gap

in federal drinking water

regulations when it

comes to drinking water

from private wells. In

Minnesota, the

Groundwater Protection

Act (Minn. Stat. 103H)

articulates that

groundwater should be

“free from any

degradation caused by

human activities.” Under

this statute, the

protection of

groundwater is the

shared responsibility of

MPCA, Minnesota Department of Agriculture (MDA), MDH, and Minnesota Department of Natural

Resources (DNR) (see Figure 5).

Though these agencies collaborate to protect groundwater used for private drinking water consumers,

MDH is the lead agency in the regulation and monitoring of water systems that distribute water to the

public. In general, states can set enforceable limits similar to federal regulatory standards (MCLs) for

public water systems if state law provides that authority – these standards can result in more stringent

protections for compounds that are already regulated under SDWA or set new limits for compounds not

regulated under SDWA, but no state can promulgate less protective regulations than those enacted by

the EPA. In Minnesota, developing and promulgating state regulatory values beyond those currently

adopted by reference from SDWA would require a significant investment in changing statutory

authority, creating a process that would likely include a cost benefit analysis in addition to the current

guidance protocol, and adding the capabilities for this expanded work.

Funding is available through SDWA to help drinking water systems comply with federal drinking water

regulations. The Drinking Water Revolving Fund (DWRF) provides below-market-rate loans and grants to

municipalities and other community drinking water systems. Loans and grants can be used to improve or

construct treatment, storage, and distribution systems. However, because PFAS are not currently

regulated under SDWA, infrastructure projects related to treatment for PFAS are less likely to rank high

on the priority list because they are not addressing a violation.

Monitoring PFAS in drinking water and groundwater

As state and federal awareness of PFAS emerged and expanded, there has been a patchwork of

monitoring efforts undertaken as needs were identified and funding was available. Minnesota is

Figure 5. State agency roles in groundwater monitoring.

Minnesota’s PFAS Blueprint • February 2021

currently working to synthesize existing data and enact a coordinated monitoring strategy for PFAS in

public water systems and groundwater that may be tapped for private or public drinking water wells.

Monitoring of finished drinking water

The federal UCMR program required all public water systems serving more than 10,000 people to

monitor for six PFAS between 2013 and 2015, which captured the community water systems (CWSs) in

Minnesota serving the largest populations, including Minneapolis, St. Paul, Rochester, Duluth, and

Bloomington. The same federal monitoring program will require additional monitoring for a larger group

of PFAS at lower detection limits from 2023 to 2025. Though this mandatory federal monitoring of

public water systems is extensive, it does not include all community water systems in Minnesota. MDH

is working to fill those gaps.

Outside of the federally-mandated monitoring for PFAS in CWSs, MDH is taking on several additional

public water system monitoring efforts. Some MDH monitoring efforts aim to explore whether there is

an impact to drinking water in known areas of concern. These projects target monitoring at systems

with higher risk for PFAS based on the location of known PFAS sources and the vulnerability to

contamination of the aquifers sourcing the drinking water. Prioritizing monitoring in these areas also

helps to protect areas of potential concern for environmental justice or health inequities, including

communities of color and small rural communities.

These trends of increased environmental burden

on communities of color are likely partially attributable to decades of zoning and housing policies

common across America that segregated these communities into areas with higher pollution and

allowed industries to develop in historically Black, Indigenous, and people of color neighborhoods. By

prioritizing PFAS monitoring at CWSs near known or anticipated PFAS sources, MDH will be able to

respond to PFAS in these communities if elevated concentrations in drinking water are found. Other

MDH drinking water monitoring projects include monitoring randomly selected CWSs, which will help

identify if there are currently unknown areas of PFAS contamination. Finally, some MDH monitoring

projects include re-sampling systems that had already been monitored for PFAS to both understand how

levels have changed over time and take advantage of new analytical methods with more PFAS analytes

and the ability to detect PFAS at lower concentrations. Accounting for the planned and ongoing

monitoring projects, MDH plans to sample approximately 295 of the 964 total CWSs in Minnesota by

2025 (see Table 3). These monitoring programs will cover approximately 4 million people, or over 90% of

the population served by CWSs.

Reed, Geena. (2019). PFAS Contamination Is an Equity Issue. Union of Concerned Scientists. Retrieved from:

https://www.ucsusa.org/sites/default/files/2019-11/abandoned-science-summary-eng.pdf ;

https://www.ucsusa.org/sites/default/files/2019-10/Appendix-Equity-Report-10-2019.pdf

Minnesota’s PFAS Blueprint • February 2021

Table 3. Summary of community water system monitoring efforts from 2006 to 2025.

In addition to monitoring CWSs, Minnesota has also sampled thousands of private drinking water wells

for PFAS near areas of known PFAS contamination. Since 2003, MDH has been investigating

groundwater contamination in the suburban communities east of St. Paul, near the 3M manufacturing

facility and its legacy waste disposal sites. To date, approximately 3,900 private wells have been sampled

in these communities. More recently, Minnesota has also been sampling private wells near firefighting

foam-contaminated sites in Bemidji and Duluth. In total, the state has collected over 20,000 samples

from approximately 4,000 private wells and continues to receive requests for sampling.

PFAS monitoring in Minnesota’s Ambient Groundwater Well Network

In order to identify trends in groundwater quality over time and have an “early warning system” for

contaminants threatening drinking water aquifers, both the MDA and MPCA have developed ambient

groundwater monitoring networks. The Minnesota Groundwater Protection Act (Minn. Stat. ch. 103H)

assigns the ambient groundwater quality monitoring responsibilities to the MDA and MPCA, with MDA

responsible for assessing agricultural chemicals (including pesticides and fertilizers), and the MPCA

responsible for assessing all other non-agricultural contaminants. The MPCA and MDA each maintain

ambient groundwater-monitoring network that, combined, provide spatial coverage of groundwater

quality conditions across the state. Funding provided by the Clean Water Legacy Amendment allowed

MPCA to expand its network of ambient groundwater wells and begin monitoring for contaminants of

emerging concern (CECs). MPCA’s network mainly is comprised of shallow monitoring wells, which

comprise an “early warning system” due to their vulnerability to contamination, but also includes some

deep wells, which represent conditions in aquifers currently used for drinking water consumption. This

monitoring network allows the agency to understand how quickly contamination from the surface is

percolating downward into aquifers used for drinking water. PFAS monitoring is not regularly included,

but the MPCA has conducted two rounds of PFAS monitoring in the full ambient groundwater network:

one round in 2013 (with limited follow up in 2017) and another round in 2019.

Connecting monitoring results and PFAS remediation projects

Minnesota is focused on monitoring drinking water and groundwater because it helps the state identify

sources of contamination, PFAS concentrations, and potential exposures so that exposures above safe

Activity

Years

Number of new

CWSs sampled

for PFAS

Number of PFAS

included

Description of CWSs sampled

PFAS Response

Monitoring

2006-

present

50*

Targeted sampling: CWSs known to have nearby

sources of PFAS

UCMR3

2013-2015

General and random sampling: All CWSs serving

> 10,000 people, some CWSs serving <10,000

people

UCMP

2019

Targeting sampling: CWSs sourced with surface

water, CWSs potentially impacted by

wastewater discharge

Statewide

PFAS

Monitoring

2020-2021

~100**

Combined targeted and random sampling:

Random selection of statewide CWSs and

additional sampling of prioritized sites

UCMR5

2023-2025

~60***

General and random sampling: All CWSs serving

> 10,000 people, all CWSs serving 3,300-10,000

people if sufficient lab capacity and funding

Totals

2005-2025

~295**

varied

*as of August 2020, monitoring is ongoing; ** subject to change ***assuming funds available for systems serving 3,300-

10,000 people

Minnesota’s PFAS Blueprint • February 2021

levels can be prevented. Sometimes drinking water or groundwater monitoring has led to the discovery

of new PFAS-contaminated sites that need to be cleaned up. In other instances, the discovery of a new

industrial PFAS source leads to targeted monitoring to ensure that potentially impacted drinking water is

not at levels that could adversely affect human health. The flow of information between the drinking

water programs in MDH and the site remediation programs and groundwater monitoring programs in

MPCA is crucial for both agencies’ success in reducing and preventing PFAS exposures. The Pilot PFAS

Inventory Project (described in the Remediation Issue Paper) combines data from MDH and MPCA to

facilitate this exchange of PFAS information.

Proactively protecting source waters from PFAS contamination

Both groundwater and surface water are used as drinking water sources in Minnesota – several state

agencies collaborate to limit pollution to all source waters for drinking water. This work is crucial in

preventing and reducing the need for treatment or other costly interventions to remove contaminants

from drinking water. MDH develops HRLs for ambient groundwater under the 1989 Groundwater

Protection Act.

These HRLs are used by partner state agencies for contextualizing the results of

groundwater water monitoring and making risk management decisions in scenarios where activities may

be impacting groundwater quality. For example, MPCA uses HRLs derived by MDH as clean-up goals at

sites with groundwater contamination.

MPCA also participates in protecting source waters for drinking water through its CWA authorities.

MPCA regulates entities discharging contaminants to the environment using Water Quality Standards

(WQS), which are the rules promulgated by Minnesota under the CWA framework to set effluent

discharge limits for permittees. Water Quality Standards are designed to protect specific “beneficial

uses,” which are definitions of how people and wildlife may be using the natural resource of surface

water. One of these beneficial uses in the CWA framework is the use of water for domestic

consumption, which includes drinking water supplies, culinary uses, and food processing uses.

Minnesota has organized water bodies into “classes” where various combinations of “beneficial uses”

apply. Class 1 is the class of waterbodies in Minnesota that includes the beneficial use of domestic

consumption, and Class 1 WQS apply to waterbodies designated in this class.

Any updates to the Class

1 WQS require rulemaking. MPCA is considering adding PFAS standards, which would eventually be used

to set any necessary limits for permittees discharging PFAS to waters used as a source of drinking water.

This would limit PFAS pollution from permitted point sources to waterbodies before they are used as

sources for private or public water consumption, potentially preventing the need for PFAS treatment or

other costly interventions at the drinking water utility or private well.

Scientific challenges

Despite the progress made in understanding the landscape of PFAS drinking water exposure in

Minnesota, challenges remain. There are thousands of compounds in PFAS family, but only about 40

PFAS have widely available analytical methods and only five PFAS have completed risk assessments from

MDH. Because toxicity data for most PFAS are not available, performing risk assessments and deriving

health-based guidance values for those compounds is currently not possible. Limitations in analytical

methods (see the Measuring PFAS effectively and Consistently Issue Paper) and toxicity analysis (see

Quantifying PFAS Risks to Human Health Issue Paper) mean that grouping PFAS for risk assessment or

regulation by chemical structure, toxicity, or other mechanism has many remaining challenges. In

The health risk limit is the concentration of a chemical in drinking water that, based on the current level of scientific

understanding, is likely to pose little or no health risk to humans, including vulnerable subpopulations. See the quantifying

human health effects issue paper for more information on PFAS health-based guidance.

More information on water quality standards can be found at: https://www.pca.state.mn.us/water/water-quality-standards

Minnesota Administrative Rules 7050.0221. Specific Water Quality Standards for Class 1 Waters of the State; Domestic

consumptions. Retrieved from: https://www.revisor.mn.gov/rules/7050.0221/

Minnesota’s PFAS Blueprint • February 2021

addition, there are currently not requirements for chemical companies to share information on the use

of PFAS and, until 2020, there were no requirements for industrial facilities to report releases of PFAS to

the environment. This lack of information about which PFAS are in use and where PFAS emissions are

occurring make it difficult to prioritize monitoring locations for drinking water. Finally, the costs and

technological capabilities of PFAS treatment systems make removing PFAS from drinking water

scientifically complex and financially burdensome (see the Managing PFAS Waste Issue Paper). All of

these challenges make it difficult to prioritize which PFAS should be investigated in drinking water and

expensive to respond to PFAS pollution when it is found.

Past and ongoing efforts

The following sections describe completed, ongoing, and planned projects related to drinking water

monitoring, drinking water interventions (providing clean drinking water), and biomonitoring of exposed

residents.

Drinking water interventions

Biomonitoring for PFAS in communities with impacted drinking water

After PFAS contamination was discovered in private and municipal wells in the Oakdale and Cottage

Grove/Lake Elmo area, drinking water treatment technologies were installed to reduce exposure in

2006. The following year, MDH was directed by Minnesota law to conduct pilot-scale biomonitoring in

two communities likely to be exposed to PFAS. This study was developed to understand how the

drinking water PFAS exposure was affecting PFAS levels in resident’s blood. The study results illustrated

that reductions in PFAS exposure from drinking water treatment resulted in a decline in PFAS blood

serum levels in the affected communities over time.

In total, three rounds of biomonitoring studies were conducted, in 2008, 2010, and 2014. The studies

followed the same group of residents over time to see how their PFAS blood levels changed. Oakdale

and Cottage Grove/Lake Elmo were selected in the initial 2008 study due to historic public and private

well contamination. Adult residents who were longer-term residents of Oakdale, Cottage Grove, and

Lake Elmo agreed to participate, providing a blood sample for PFAS testing and answering a short

survey. The 2014 study also included a group of newer Oakdale residents who moved to the area after

drinking water treatment was in place.

Biomonitoring results from this study demonstrated that these East Metro residents had considerably

higher blood levels for PFOS, PFOA, and PFHxS than the general population of the US. Blood levels of

PFOS, PFOA, and PFHxS declined in long-term East Metro residents over the six-year period, though they

remained higher than the US population. PFAS levels were related to the number of years they drank

untreated water in the East Metro before the drinking water treatment began and other factors. PFAS

blood levels in the newer residents, who moved in after treatment began, were similar to the US

population. This study was not designed to assess health impacts of PFAS.

Results from the biomonitoring studies demonstrated that efforts to reduce drinking water exposure to

PFAS in the East Metro were successful in reducing PFAS blood levels. Due to the body’s poor ability to

get rid of PFOS, PFOA, and PFHxS, as well as ongoing exposures from sources beyond drinking water

(e.g., diet, household dust, consumer products) these chemicals are still elevated in the blood of long-

term East Metro residents even after a decade or more of public health interventions. MDH anticipates

that, over time, East Metro residents’ blood levels will continue to decline to the “background” level.

Minnesota’s PFAS Blueprint • February 2021

Work status: completed

Leaders: MDH Chronic Disease & Environmental Epidemiology Section, MDH Biomonitoring

program, MDH PHL, MDH Environmental Health Division. Partners: East Metro communities, MPCA

Remediation Division, Environmental Health Tracking and Biomonitoring Science Advisory Panel,

local public health agencies.

Benefits: These studies were conducted to more fully understand the impact of contaminated

drinking water on blood levels of PFAS in Minnesotans, and to determine whether public health

interventions to reduce PFAS in drinking water were effective in reducing blood levels. The studies

allowed MDH to analyze some demographic characteristics: MDH did not find differences in PFAS

blood levels between people who rent verses own their homes, or between people of different

income levels. Some PFAS were higher in non-Hispanic White people compared to other groups.

Challenges: PFAS biomonitoring is a time and resource-intensive endeavor. Developing robust and

accurate laboratory methods needed to analyze PFAS in blood was challenging. Recruitment of

participants using epidemiologic methods and collecting blood samples also required significant

time and resources, particularly tracking participants over the course of many years. Careful public

messaging and engagement with the community in the areas of risk communication and outreach

also was resource intensive, requiring a long-term, sustained effort. Outreach to health care

providers in the affected areas was another important area of attention. As PFAS blood testing is not

a standard clinical test, providers needed background information and support to help their patients

understand their blood testing results. Finally, working with different divisions of MDH and other

state agencies, community members, elected officials, local public health officials, and the

Environmental Health Tracking and Biomonitoring Science Advisory Panel all required thoughtful

planning and coordination.

Resources: This project involved significant staff time for approximately eight years. The first round

of biomonitoring conducted in 2008 cost approximately $250,000 for sampling and analysis.

Subsequent rounds of biomonitoring had similar costs.

Drinking water and groundwater monitoring

Third Unregulated Contaminant Monitoring Rule (UCMR3) (2013-2015)

Every five years, the EPA implements the UCMR. The purpose of UCMR is to collect data from across the

country on contaminants that may be present in drinking water. EPA uses this data to decide if the

contaminants occur at frequencies and concentrations high enough to be regulated in the future. The

third round of UCMR, UCMR3, required monitoring for 30 contaminants, including six PFAS (PFOA, PFOS,

PFNA, PFHxA, PFHxS, PFBS), between 2013 and 2015. UCMR3 included all CWS serving more than 10,000

people and a statistically representative subset of systems serving 10,000 or fewer people. In Minnesota,

MDH covered the analytical costs of UCMR sampling in large systems, while the EPA covered the

analytical costs for small systems. From 2013-2015, 98 CWS were sampled; 55 of these were sampled for

PFAS for the first time. MDH detected PFAS at five CWS: Oakdale, Bemidji, Hastings, Woodbury, and

Cottage Grove. Bemidji was the only CWS where PFAS had not previously been detected. MDH worked

with these CWSs to conduct on-going monitoring and discuss options for treatment. Data resulting from

UCMR3 monitoring can be found at EPA website or the consumer confidence reports from any CWS that

participated in monitoring.

EPA (n.d.) Occurrence Data for the Unregulated Contaminant Monitoring Rule. Retrieved from:

https://www.epa.gov/dwucmr/occurrence-data-unregulated-contaminant-monitoring-rule#3

Minnesota’s PFAS Blueprint • February 2021

Work status: completed

Leaders: MDH Drinking Water Protection Section and EPA Office of Ground Water and Drinking

Water. Partner: Public water suppliers.

Benefits: Participation in UCMR monitoring is mandated by the EPA, but the resulting data are

useful for understanding the landscape of potential contaminants of emerging concern. This

surveillance for PFAS in Minnesota and nation-wide drinking water is being used to support federal

regulation for PFAS under SDWA. The resulting data also identified one location in Minnesota where

further monitoring, interventions to reduce PFAS concentrations in drinking water, and

investigations into PFAS sources were warranted. The reductions in PFAS resulting from voluntary

interventions following monitoring directly benefited Minnesotans by reducing PFAS exposure for

drinking water consumers.

Challenges: Data collected as part of UCMR3 was useful in identifying previously unknown locations

of PFAS in drinking water, but this survey had some limitations. Perfluorobutanoic acid (PFBA) was

not included in UCMR3 sampling -- MPCA and MDH are now aware that PFBA is the most commonly

detected PFAS in drinking water in Minnesota. Additionally, detection limits for sampling during

UCMR3 were higher than detection limits that can be achieved currently. Notably, current HRLs for

some PFAS are lower than UCMR3 detection limits for those compounds, meaning that a result

reported as non-detect could still be an exceedance of an HRL. The number of systems with PFAS

detections in UCMR3 may have been higher if PFBA had been one of the included contaminants or if

detection limits had been lower. MDH is conducting several other monitoring initiatives to resample

systems included in UCMR3, sample small systems not included in UCMR3, and sample private

drinking water wells, which are not included in UCMR surveys.

Resources: MDH engineers helped conduct sampling and staff oversaw the project completion. MN

covered the analytical for sampling in large systems (~$90,000), EPA covered the analytical costs for

small systems.

PFAS Response Monitoring (2006 – ongoing)

The goal of the PFAS Response Monitoring project is to provide ongoing monitoring support to CWS that

may be impacted by PFAS contamination as new PFAS sites are discovered. MDH has conducted ongoing

sampling at 13 CWSs in the East Metro. Overall, approximately 250 samples are collected each year at

these 13 CWSs. Response monitoring for PFAS also occurred in 2008 to investigate drinking water

supplies near firefighting training sites known to be associated with use of PFAS-containing AFFF). MDH

has additionally sampled 37 other CWSs for PFAS that are not associated with either the East Metro

community or near AFFF sites. There is an ongoing collaboration between MPCA and MDH to share data

and identify locations where drinking water monitoring is warranted based on potential impacts from

PFAS pollution. This response monitoring effort also includes monitoring for PFAS in private drinking

water wells. Approximately 3,900 private wells have been sampled in the East Metro area communities.

More recently, the state has also been sampling private wells near AFFF sites in Bemidji and Duluth. To

date, the state has collected over 20,000 samples from approximately 4,000 private wells. Drinking

water advisories, based on health-based drinking water guidance values from MDH, have been issued to

approximately 1,300 wells.

Work status: ongoing

Leader: MDH Drinking Water Protection Section. Partners: MPCA Remediation, participating public

water suppliers, participating private well owners.

Benefits: This ongoing project allows MDH and partnering groups to monitor for PFAS in drinking

water systems near known PFAS sources. Having a program in place to conduct this monitoring

allows for more efficient collaboration between MDH and MPCA and a faster response when new

Minnesota’s PFAS Blueprint • February 2021

PFAS sites with potential drinking water impacts are discovered. This timely response, prepared

communication plans, and the dedicated time of various hydrologists and engineers helps to

minimize community concern if an issue arises. This response sampling has also added to MDH and

MPCA’s general understanding of the overall burden of PFAS in Minnesota drinking water.

Challenges: There are no mandatory PFAS emission reporting requirements currently in place, and

future regulations on PFAS emission reporting by the EPA under the Toxics Release Inventory (TRI)

will not require all PFAS emissions to be reported. This lack of information about industrial PFAS

sources makes it difficult to identify potential PFAS sources impacting drinking water. There is a lack

of drinking water regulations (MCLs) for PFAS, meaning that drinking water systems are not

compelled to take actions if there are exceedances of health-risk levels. Financing treatment

systems can also be a challenge, especially if there is not a “responsible party” under the Superfund

program identified.

Resources: This effort involves multiple staff from MDH overseeing these drinking water monitoring

efforts. Staff help with communication and coordination with water systems, formulating sampling

plans, and providing expertise on PFAS hydrology. Some sampling associated with PFAS remediation

sites can be funded through MPCA.

Unregulated Contaminant Monitoring Project (2019 - 2021)

The goal of the Unregulated Contaminant Monitoring Project (UCMP) is to understand the presence and

abundance of a large number of unregulated contaminants in surface water, vulnerable groundwater

drinking water sources, and finished drinking water around the state. The contaminants included in

UCMP were selected based on detection in previous monitoring studies and public health interest – 30

PFAS were included alongside approximately 100 other analytes. In this effort, MDH has collected PFAS

samples from 46 CWSs using surface water as a drinking water source or using groundwater that is

potentially impacted by wastewater. Of the included systems, 30 had not previously been monitored for

PFAS. Potential for wastewater impacts in groundwater was determined using past detections of

contaminants associated with wastewater and geologic considerations. United States Geological Survey

(USGS) collaborated in designing the monitoring plan and are currently assisting in analyzing results.

Once complete, the results from this monitoring effort will be published in a publicly available report. If

results from monitoring indicate that additional actions are needed to protect consumers, MDH will

work with the CWSs and involve the MPCA Remediation program as needed.

Work status: ongoing

Leaders: MDH Drinking Water Protection and USGS Water Science Center. Partner: Participating

public water suppliers, MPCA Remediation, MDA Pesticide Monitoring Group.

Benefits: Surface water and vulnerable groundwater are the most likely drinking water sources to be

impacted by anthropogenic contaminants like PFAS. By focusing monitoring on drinking water

systems that are most vulnerable, resources will be prioritized towards the most likely areas of

concern. If there are exceedances of health-based values for any of these emerging contaminants,

proactive monitoring will inform the need for additional monitoring and possibly interventions to

reduce exposure.

Challenges: This is a large, interdisciplinary project that required significant one-time financial

contributions to get off the ground. Continued work depends on additional funding. Analytical

support from USGS continues to be especially helpful.

Resources: Several staff are involved in overseeing this project, including a project manager, and an

advisory group with staff from MPCA, MDA, and USGS. There are additionally two full-time samplers

who collected samples for this project. This project was made possible by funding from the

Environment and Natural Resources Trust Fund, which contributed $1 million.

Minnesota’s PFAS Blueprint • February 2021

Statewide PFAS Monitoring Program (2020-2021)

The goal of this project is to monitor prioritized drinking water systems for PFAS and a select number of

randomly selected drinking water systems. MDH has identified methods for assessing the vulnerability

of aquifers to anthropogenic contaminants like PFAS, and has categorized aquifers into either

“vulnerable” or “non-vulnerable” categories. This project is similar to the Unregulated Contaminant

monitoring project in that it focuses on CWSs that are sourced from vulnerable aquifers; however, it

prioritizes sites near known or suspected PFAS sources, only involves monitoring of PFAS analytes,

includes a larger group of CWSs, and includes a number of non-community water systems. This effort is

funded by EPA though a Multi-Purpose Grant and through the CWF. MDH collaborated with MPCA to

determine high-priority systems based on proximity to sites anticipated to have PFAS uses, proximity to

known PFAS contamination, and the vulnerability of the source waters. As part of this effort, MDH will

resample approximately 30 CWSs near AFFF sites that had previously been monitored. This resampling is

beneficial because current methods include a larger list of PFAS analytes and lower detection limits than

previous methods could achieve. MDH will work with water systems if any next steps are needed. Some

funding from this project will be set aside for following up on results of the previously described

initiative, “targeted monitoring near likely PFAS sources.”

Work status: ongoing

Leaders: MDH Drinking Water Protection and MPCA Remediation Division. Partner: Participating

public water suppliers.

Benefits: This project specifically targets drinking water systems located near potential PFAS

emission sites and vulnerable to contamination. Prioritizing monitoring in these sites will allow MDH

to assist water systems with addressing PFAS contamination as quickly as possible, if such

interventions are shown to be needed. The communities included in this sampling effort represent a

variety of households, neighborhoods, and socioeconomic groups. Because this project will also

randomly select systems to monitor, it may help MDH and MPCA find currently unknown PFAS

contamination sources.

Challenges: The lack of PFAS labeling and use and emissions reporting requirements makes it

difficult to identify industries or facilities that have historically used or may be currently using PFAS –

assumptions based on known PFAS uses in certain industries are relied on to identify potential PFAS

sources instead of more concrete data. Convincing water systems to participate in this voluntary

monitoring effort can also be a challenge – because PFAS is not regulated on the federal level (there

are no MCLs), discovering PFAS contamination in exceedance of health-risk values does not result in

prioritization for funding through the DWRF.

Resources: Several staff from MDH and MPCA assist in project management and planning. One staff

from MDH dedicated several months to collecting samples from participating CWSs. The EPA Multi-

purpose Grant (MPG) includes $88,000 during Fiscal Year (FY) 2019 and an additional $63,000 in FY

2020 funds dedicated to sampling drinking water. This effort will additionally be funded through the

CWF.

Measuring PFAS in the Ambient Groundwater Monitoring Network

The Minnesota Groundwater Protection Act (Minn. Stat. ch. 103H) splits the ambient groundwater

quality monitoring responsibilities between the MDA and MPCA, which each agency maintaining their

own ambient groundwater-monitoring network that, combined, provides good spatial coverage of

groundwater quality conditions across agricultural regions and non-agricultural regions in the state. The

MPCA’s ambient groundwater monitoring primarily targets aquifers in urbanized parts of the state, and

contaminants included in monitoring generally do not include agricultural compounds like pesticides.

MPCA’s network mainly is comprised of shallow monitoring wells which intersect the water table but

Minnesota’s PFAS Blueprint • February 2021

also includes some deep wells. The shallow wells, which have a median depth of 22 feet, comprise an

“early warning system” and allow the Agency to understand what chemicals can readily be transported

to the groundwater and identify emerging trends in groundwater quality. The deep wells, which

primarily are domestic wells installed in the Prairie du Chien-Jordan aquifer, provide information on the

quality of the water that is consumed by Minnesotans and information about how quickly any

contamination from the surface is percolating downward.

Funding from the CWF allowed the MPCA to install shallow monitoring wells in key areas where existing

wells were not available, such as residential areas that use subsurface sewage treatment systems for

wastewater disposal, and commercial or industrial areas. This funding also allowed the MPCA to expand

the list of chemicals it routinely analyzed in water samples to include CECs. MPCA has also been able to

do some specific, non-routine, sampling for PFAS. In 2013, with limited targeted follow-up in 2017,

MPCA was able to include 13 PFAS analytes in the analysis of groundwater samples. The results of PFAS

monitoring are available in a report on MPCA’s website.

This report shows that PFAS were detected in

most groundwater in the state, with PFBA being the most frequently detected PFAS (found in almost

70% of all sampled wells). In 2013, PFOA was detected in 30% of sampled wells, PFOS was detected in

12% of sampled wells, and PFHxS was detected in 11% of sampled wells.

An additional special sampling of the whole network was completed in 2019, and included 33 PFAS

analytes. Preliminary analysis shows that 17 of the 33 analytes were detected. PFBS was detected in

42.4% of the groundwater wells in 2019, higher than the 9% presence seen in 2013, likely due to the

lower analytical method reporting limits. Three PFAS (PFOA, PFOS, and PFHxS) were detected at least

once at concentrations above MDH’s health-based guidance. Samples with detections were primarily in

shallow monitoring wells, but some detections were in deeper monitoring wells.

Funding for PFAS monitoring in the Ambient Groundwater Well Network has not been specifically

provided. MPCA has done the sampling as resources become available. To continue monitoring for PFAS

in this network, additional funding would be needed.

Work status: ongoing, additional funding for continued PFAS monitoring would be needed

Leader: MPCA Environmental Analysis and Outcomes Division.

Benefits: Though many of the wells in the ambient groundwater well network tap into shallow,

unprotected aquifers that are not used for drinking water, these wells provide an early warning

system for contaminants that may contaminant drinking water aquifers in the future. Some of the

wells in the network do sample drinking water aquifers – detections in these aquifers are important

for assessing if there are currently potential human health risks due to drinking water exposure. This

ambient well network helps the Agency identify unknown sources of PFAS exposure and assess

potential near-term or long-term threats to the quality of Minnesota’s drinking water aquifers.

Challenges: PFAS analysis is more expensive than monitoring for many other environmental

contaminants – continued funding is required to ensure that PFAS monitoring in this network can

proceed in the future. Additionally, the only PFAS that can be monitored for in this network are

those with available analytical methods. In the most recent round of PFAS monitoring, samples were

shipped to a lab in Canada with the capacity to monitor 33 PFAS analytes with low detection limits –

it requires additional cost, staff time, and effort to ship a large number of samples internationally.

Many PFAS without methods available may be present in groundwater and not be detected with

current analytical approaches.

MPCA. (n.d.) Groundwater data. https://www.pca.state.mn.us/water/groundwater-data

Additional information is available on request from the MPCA (memo: 2019 Ambient Groundwater Sampling Results)

Minnesota’s PFAS Blueprint • February 2021

Resources: Including PFAS analysis in one complete round of ambient groundwater monitoring costs

approximately $100,000.

Communications

Developing communication tools for drinking water systems and the general public

Developing communication plans and materials based on social science research is essential for effective

communications with public water systems and the public when conducting PFAS monitoring in drinking

water. MDH staff work closely with CWSs before sampling begins to explain the importance of

understanding levels of these unregulated contaminants – because PFAS are unregulated, CWSs have no

requirements to participate in monitoring. MDH develops communication guides and action plans for

how to respond to various scenarios that may emerge as a result of unregulated contaminant

monitoring. For example, MDH may meet with cities if steps like additional sampling or other

investigations are needed, provide technical information about health effects to relevant local partners,

and help craft informational messages for water consumers. MDH continues to develop informative and

appropriate communication materials related to PFAS for various audiences as needs arise. MDH has

developed an online Drinking Water Risk Communication Toolkit to support public water systems’

communication efforts with their customers.

Work status: ongoing

Leader: MDH Drinking Water Protection. Partner: Participating public drinking water systems.

Benefits: Effective, science-based communication materials allow MDH to explain steps MDH is

taking to address PFAS in drinking water and why it is important to monitor for PFAS. MDH also

helps facilitate discussions - both if a risk to public health arises and when the agency identifies no

health risks.

Challenges: Communicating around PFAS contamination can be especially challenging due to the

uncertainties and data gaps for the broad class of compounds. Additionally, the health-based

guidance for several PFAS are derived specifically to be protective of vulnerable populations like

fetuses and infants that could be exposed via mothers -- nuanced messages are needed to explain

these complexities. Developing informative yet effective resources requires collaboration of many

topic experts and communication staff.

Resources: Communication specialists at MDH help with website, information sheets, message

blocks and other materials; also with designing public meetings, risk communication, and related

outreach. Communication staff draft materials in collaboration with subject matter experts and

coordinate with relevant outside partners. MDH also contracts with translation services to ensure

health information is available to all impacted groups.

Gaps and opportunities

Despite the significant ongoing effort to monitor PFAS in drinking water, opportunities remain to

continue to fill gaps in drinking water monitoring, drinking water regulations, and protecting source

waters from PFAS contamination using CWA standards. The sections below describe two projects that

are planned to help fill gaps in monitoring and source water protection. No additional authorities would

be required to undertake those planned projects within MPCA or MDH programs, though support from

the legislative branch and the public would be helpful for rulemaking related to CWA standards. Planned

and ongoing drinking water monitoring projects would capture approximate 90% of all community

water consumers by 2025, but additional funding would be needed to expand these projects to capture

MDH. (n.d.). Drinking Water Risk Communication Toolkit. Retrieved from:

https://www.health.state.mn.us/communities/environment/water/toolkit/index.html

Minnesota’s PFAS Blueprint • February 2021

all community water consumers or to conduct planned monitoring on a compressed timescale. A third

project describes the possibility of evaluating the processes that would be needed to develop state

drinking water regulations for contaminants with no federal drinking water regulations or regulations

that do not incorporate the most recent science. This project would a long-term initiative.

There are no federal or state standards (MCLs) limiting PFAS concentrations in drinking water. Though

PFAS are currently unregulated by the EPA in drinking water, the EPA has recently begun the process of

possibly regulating two PFAS – PFOA and PFOS. In the announcement of this decision, the EPA also

discussed PFAS grouping strategies that may be appropriate for a future federal rule. The implementation

of federal PFAS standards for drinking water is not likely to go into effect until at least 2025.

Currently, if CWSs or private wells in Minnesota exceed MDH’s non-regulatory health-based guidance,

MDH has procedures in place to alert water systems and private consumers, and to support systems or

households in taking voluntary actions to reduce exposure. MDH can support systems by giving advice

on blending water or applying treatment aimed at reducing PFAS concentrations to below health-based

guidance values. MDH also supports private well owners in installing and maintaining point-of-use filters

that remove PFAS from water. So far, drinking water advisories, based on Minnesota’s health-based

drinking water guidance values, have been issued to approximately 1,300 private well owners. Eight

CWSs have treatment or other management plans in place to reduce PFAS concentrations to safe levels.

Regulation, either a state or federal MCL, could benefit consumers by mandating testing of public water

systems, increasing the availability of funding for treatment, having statewide standards that could be

used as clean-up levels in federal clean-up projects, and adding visibility to PFAS source reduction

efforts. Fortunately, to date, the desire of communities to provide a trustworthy water supply and

access to financial resources for treatment has translated into protective public health actions that

address PFAS contamination in both public and private water systems. However, as our understanding

of the extent and sources of PFAS contamination in water expands, this may not continue to be the case.

The option to pursue the establishment of state regulatory values has arisen in informal discussions at

MDH. Developing and promulgating state regulatory values beyond those currently adopted by

reference from the federal SDWA would require a significant investment in changing statutory authority,

creating a process that would likely include a cost benefit analysis in addition to the current guidance

protocol, and adding the capabilities for this expanded work. Given the current context and agency

commitment to responding to COVID-19, weighing the pros and cons of state regulatory values awaits

the restoration of full staff capacity for core functions and workload. Until then, Minnesota will continue

to rely on the good will and relationships established with community water systems and commitments

to finding the necessary resources for treatment as new areas of PFAS contamination are discovered.

Given the widespread PFAS monitoring in CWS and the voluntary actions on the part of drinking water

utilities to meet health-based guidance values for drinking water, MDH is not currently developing

drinking water standards for PFAS at this time. The process to develop a state MCL regulatory process

and program would take a considerable amount of time and resources, and the federal government is in

the midst of SDWA rulemaking for PFAS. Though there are benefits to having drinking water regulations

for PFAS, MDH is currently focusing on monitoring PFAS in drinking water and collaborating with MPCA

on source water protection efforts.

Future drinking water monitoring

Conduct drinking water monitoring under the Fifth Unregulated Contaminant Monitoring Rule

(UCMR5) (2023-2025)

The next round of UCMR monitoring will take place in Minnesota between 2023 and 2025. This

monitoring is currently scheduled to include, at a minimum, 29 PFAS, including PFBA. UCMR5 will

include lower reporting limits than UCMR3 and, due to changes in UCMR monitoring requirements, will

Minnesota’s PFAS Blueprint • February 2021

include all systems serving greater than 3,300 residents (assuming sufficient funding and lab capacity).

MDH estimates that 180 CWSs will be included in UCMR5 monitoring, 58 of which will be sampled for

PFAS for the first time.

Work status: planned – required participation under the Safe Drinking Water Act

Leaders: MDH Drinking Water Protection and EPA Office of Water. Partner: Participating public

water suppliers.

Benefits: Monitoring for a longer list of PFAS analytes at lower detection limits and the increased

scope of UCMR to include all systems serving between 3,300 and 10,000 residents will be helpful in

broadening the understanding of PFAS contamination in drinking water state-wide. The federal

government will cover analytical costs for sampling at participating small drinking water systems,

and MDH will cover analytical costs for large systems. MDH will also provide guidance to CWSs on

communication, outreach, and potential interventions to reduce PFAS concentrations (if needed).

Challenges: The inclusion of the new EPA Method 533 in addition to the EPA Method 537.1 will

likely increase the time required to process samples and increase the cost of monitoring compared

to UCMR3.

Resources: MDH engineers will help conduct sampling and staff will oversee the project completion.

MDH will cover the analytical for sampling in large systems, which will likely be higher than the costs

associated with UCMR3 (~$90,000) due to the new method including more analytes and lower

detection limits. EPA will cover the analytical costs for small systems.

Future considerations for regulation

Develop Clean Water Act Water Quality Standards for Class 1 waters

The Clean Water Act (CWA) is a federal law that allows states to protect surface waters by determining

the “beneficial uses” of the waterbody, and setting WQS to protect those uses. States then monitor

waterbodies to compare levels of pollution to the applicable standards and list waterbodies as

“impaired” if they exceed the WQS and therefore do not meet their beneficial uses. States also permit

facilities that discharge into waters in order to ensure that their discharges do not have the reasonable

potential to cause or contribute to an exceedance of any WQS. Examples of beneficial uses for

waterbodies include things like recreating, fishing, irrigation, and aesthetic enjoyment. One important

beneficial use designation in Minnesota is “domestic consumption,” which protects water so it can be

used as a drinking water supply, in food processing, and other related activities. Minnesota groups

waterbodies based on combinations of designated uses that apply to the waterbodies, and derives WQS

for those classes. Waterbodies with “domestic consumption” beneficial use designations are protected

by Class 1 WQS under Minn. R. ch. 7050.

The MPCA is currently reviewing and planning to update Minnesota’s Class 1 WQS, including where they

are applied and the narrative or numeric water quality standards needed to ensure the water meets the

beneficial use. The agency is considering adding numeric Class 1 WQS for multiple pollutants, including

PFAS.

The existing Class 1 WQS include the maximum contaminant levels (MCLs) and secondary drinking water

standards developed under the federal SDWA, which are incorporated into Minnesota’s WQS by

reference. Currently there are no SDWA standards (MCLs) for PFAS. Because the MCLs are derived for

application to finished (and in most cases, treated) drinking water, they are not ideal for protecting

source waters in their natural state. Also, most MCLs were developed prior to 2000, and consequently

there are no standards for recently recognized pollutants of concern. For both reasons, MPCA is

considering revising the Class 1 WQS and potentially adding standards for PFAS along with other

Minnesota’s PFAS Blueprint • February 2021

recently recognized pollutants of concern such as pharmaceuticals, algal toxins, and certain pesticides

and industrial chemicals.

MPCA anticipates that any new approach to developing and/or adding Class 1 WQS to Minn. R. 7050 will

be based on the approach developed for human health protection by the MDH and used to develop

Health Risk Limits (HRLs) or Health Based Values (HBVs) for groundwater. Among other benefits, this

would enable MPCA to utilize MDH’s toxicological risk assessments to develop Class 1 WQS. Accordingly,

Class 1 WQS could be adopted for pollutants for which MDH has developed a HRL or HBV – which

currently includes PFOA, PFOS, PFHxS, PFBA, and PFBS. Any changes would go through the rulemaking

process, with multiple opportunities for public engagement. See the Reducing PFAS Exposure from

Consuming Fish and Game Issue Paper for discussion of WQS protective of people consuming fish and

the Managing PFAS in Waste Issue Paper for a general discussion WQS in the context of waste facilities.

Work status: planned

Leaders: MPCA Water Quality Standards Unit.

Benefits: Updating the Class 1 WQS will improve the foundation for protecting Minnesota’s source

waters by introducing standards that are health protective and developed based on current science.

Once adopted, the Class 1 WQS will be available to evaluate discharges that are subject to

regulation through National Pollutant Discharge Elimination System/State Disposa System

(NPDES/SDS) permits, which will facilitate any needed actions to reduce the loading of PFAS from

regulated dischargers to surface waters that supply drinking water. In addition, with adoption of

Class 1 WQS for PFAS, these contaminants would likely be added to those that are monitored as part

of the watershed monitoring program for waters classified as Class 1. Should this monitoring result

in identification of an impaired waterbody, development of a total maximum daily load (TMDL) plan

to address the impairment would follow.

Challenges: WQS are a regulatory tool that often carry significant economic impacts to permittees.

While the cost of discharging environmental pollutants that are harmful to human health and the

environment should be borne by the entities generating that pollution, there are some permittees

like wastewater treatment plants (WWTPs) that are not likely to generate significant PFAS or

purchase PFAS products, but instead pass other commercial and industrial PFAS through to the

environment. The economic reality of meeting new and revised discharge requirements can be

daunting to those permittees like WWTPs. This is likely more true for PFAS than is typical, given the

complexities and costs associated with designing and operating treatment in complex waste streams

like effluent.

Strategies like implementing industrial pre-treatment programs have been shown in other states to

be successful at significantly reducing PFAS loads to WWTPs and passing the financial burden of

PFAS pollution to the industrial producers and users of the compounds.

Industrial pre-treatment

may not be enough to reduce PFAS loads down to levels below health-based standards in all cases.

Additional strategies to reduce PFAS pollution at the source (see Preventing PFAS Pollution Issue

Paper) could also significantly reduce the PFAS loading to permittees such as WWTPs. However,

even with concurrent actions to reduce PFAS sources to WWTPs and other permittees that act as

“conduits” rather than PFAS sources, CWA tools like variances may be still necessary to meet health-

based standards for PFAS. MPCA would need to work closely with the EPA and regulated parties to

chart a feasible and strategic path forward for ensuring that discharges of PFAS do not occur at

levels that could cause exceedances of health-based guidance for drinking water.

EGLE (n.d.). IPP PFAS Initiative. Retrieved from: https://www.michigan.gov/egle/0,9429,7-135-

3313_71618_3682_3683_3721-531869--,00.html

Minnesota’s PFAS Blueprint • February 2021

Once adopted, a WQS for PFAS would likely require periodic revision to incorporate the rapidly

expanding knowledge about PFAS fate, transport, and toxicity. These revisions to future PFAS WQS

trigger additional rulemaking, which is a time consuming and politically intensive process.

Finally, PFAS monitoring is generally more expensive than monitoring for other contaminants.

Currently, costs for PFAS monitoring range from $300-400 per sample. Monitoring Class 1 waters for

PFAS to determine if they are meeting their designated use would increase the costs to the MPCA’s

regular watershed monitoring program, and would likely require additional resources.

Resources: Development of WQS typically requires significant staff resources over an extended

period of time to develop the scientific, technologic, and economic analyses that are required for

WQS promulgation. The upfront scientific work and development of the technical support

documents usually falls to staff in the WQS unit; once a rule begins to move forward into

rulemaking, significant effort is needed to ready the project for promulgation via Minnesota’s

Administrative Procedures Act. WQS development and promulgation is routine business of the

MPCA, but monitoring for PFAS in Class 1 waters for drinking water would increase costs associated

with watershed monitoring programs.

Evaluating options for managing risks from federally unregulated contaminants

The lack of enforceable federal standards for PFAS has led to a patchwork of state approaches to

managing the risks in drinking water. In the continuum of approaches that extends from state regulatory

numbers all the way to essentially no action, Minnesota sits in the middle. Minnesota was the first to

develop health-based guidance values that are advisory in nature and has not pursued regulatory

standards at the state level to date. Fortunately, the desire of communities to provide a trustworthy

water supply and access to financial resources for treatment has translated into protective public health

actions that address PFAS contamination in both public and private water systems. However, as our

understanding of the extent and sources of PFAS contamination in water expands, this may not continue

to be the case.

Developing and promulgating state regulatory values beyond those currently adopted by reference from

SDWA would require a significant investment in changing statutory authority, creating a process that

would likely include a cost benefit analysis in addition to the current guidance protocol, and adding the

capabilities for this expanded work. The Minnesota Department of Health’s (MDH) preferred approach is

to adopt federal drinking water standards developed by the EPA into Minnesota rules by reference.

However, EPA has been slow to regulate PFAS, and may not ultimately regulate PFAS at levels that are

health-protective. Given the current context and agency commitment to responding to COVID-19,

weighing the pros and cons of state regulatory values awaits the restoration of full staff capacity for core

functions and workload. However, once MDH returns to full staff capacity, the agency will consider the

needs and challenges associated with developing state regulatory values for drinking water.

Leader: MDH Environmental Health Division.

Benefits: Regulation, either a state or federal MCL, could benefit consumers by mandating testing of

public water systems and increasing the availability of funding for treatment. Having statewide

standards that could (along with existing HRLs) be considered applicable or relevant and appropriate

requirements (ARARs) in federal clean-up projects would be beneficial (see the Remediating PFAS

Contaminated Sites Issue Paper for more information on ARARs). A state process for developing

drinking water standards could also be helpful for managing the increasing number of other

federally unregulated contaminants or contaminants with federal regulations that do not consider

current scientific literature.

Minnesota’s PFAS Blueprint • February 2021

Challenges: The process to develop a state MCL regulatory process and program would take a

considerable amount of time and resources. MDH would solicit input from stakeholders, including

the water industry, local government partners and a diverse set of citizens.

Resources: Significant resources would be needed to reach out to stakeholders and assess the pros

and cons of moving forward with state regulatory values for drinking water.

Overview of intersectional issues

 Pollution prevention: Reducing PFAS pollution at the source places the cost burden of

treatment with the polluters rather than receptors, like drinking water consumers and publicly-

owned utilities. See the PFAS Pollution Prevention (P2) issue paper for actions related to

reducing the overall production and emission of PFAS products.

 Quantifying PFAS toxicity: Understanding of the potential health impacts of PFAS exposure is

key in ensuring exposure stays below “safe” thresholds and communicating with the public.

Health-based guidance values, however, require data on toxicity and exposure that are not

available for the vast majority of all the PFAS found in the environment. See the Quantifying

PFAS Risks to Human Health Issue Paper for more information on challenges stemming from

PFAS toxicity data limitations.

 Developing and expanding access to analytical methods: Analytical methods for PFAS are

expensive and time-intensive to run, and include only a subset of all PFAS that may be occurring

in drinking water. Non-targeted methods are a promising alternative tool to determine the

landscape of PFAS occurring in many media, including drinking water, but additional resources

are needed to expand access to this new methodological approach – see the Measuring PFAS

Effectively and Consistently Issue Paper for more information on the costs and challenges

associated with measuring PFAS in various matrixes.

 Remediating PFAS contaminated sites: Because costs associated with treating PFAS

contamination can be very high, identifying responsible parties for pollution can be important in

assisting with costs of drinking water treatment – see the Remediating PFAS-contaminated Sites

issue paper for more information on identifying sites with ongoing or historic PFAS

contamination.

Minnesota’s PFAS Blueprint • February 2021

Background

 Hunting and fishing are cherished activities in Minnesota, with long-standing cultural significance for

many populations. In some cases, locally harvested fish and game are relied on as healthy sources of

protein and a key component of a family’s diet.

 Nearly all of Minnesota is ceded territory, and members of tribal nations retain hunting, fishing, and

gathering rights.

 Continued research on PFAS in fish and wildlife has indicated that some PFAS can accumulate in

commonly consumed tissues of fish and game, potentially to levels causing health concerns for those

consuming the meat.

 Several agencies in Minnesota participate in monitoring PFAS in fish and game, providing

consumption advice, and regulating PFAS discharges with the intention of removing the need for

consumption advice in the future.

 The Fish Contaminant Monitoring Program (FCMP) is an inter-agency group including staff from

MDH, MPCA, and DNR that collects fish from lakes and rivers throughout Minnesota. The resulting

fish tissue data is used to inform scientific understanding of accumulation patterns in fish, issue fish

consumption advice, and develop water quality standards protective of fish consumers.

 MDH is responsible for providing statewide and site-specific fish consumption advice.

 Statewide advice is developed based on mercury and PCB levels found in fish harvested around the

state. Site-specific advice is developed if local levels of PCB, mercury, or PFOS contamination

warrant more restrictive consumption advice than would apply statewide.

 MPCA can develop statewide water quality standards and site-specific water quality criteria

protective of fish consumers under the CWA.

 There are no statewide water quality standards for PFAS, but there are site-specific water quality

criteria in waterbodies with known PFAS contamination, including in the East Metro region.

 The DNR can conduct monitoring of PFAS in commonly consumed game, as funding and capacity

allows.

What is Minnesota doing now?

 Monitoring: The FCMP has monitored for PFAS in fish from 178 lakes and 12 rivers, but does not

include PFAS as part of routine analysis of fish collected in the monitoring program. Additionally, the

DNR is conducting a pilot project to monitor PFAS levels in deer harvested in regions with known PFAS

surface water contamination.

 Advice: The MDH has provided site-specific fish consumption advice for PFOS in some waterbodies.

 Regulation: MPCA has issued site-specific water quality criteria for PFOS protective of fish consumers

applicable to waterbodies with known PFAS surface water contamination.

Reducing PFAS exposure from consuming fish and game

Summary

Minnesota’s PFAS Blueprint • February 2021

What are remaining gaps and opportunities for action?

 Gap: The Interagency FCMP collects fish from lakes and rivers throughout Minnesota. Though this

group has conducted some PFAS analyses through this monitoring program, funding has not been

available to routinely include PFAS widely in monitoring efforts.

 Opportunity: Sustained ongoing funding for monitoring PFAS in fish would provide updated fish

contaminant data for the impaired waters inventory (MPCA) and fish consumption guidance

(MDH).

 Gap: There is limited information about PFAS concentrations in edible tissues of game, especially game

harvested near areas with surface water or soil PFAS contamination.

 Opportunity: DNR could continue the existing pilot monitoring project underway for PFAS in deer.

DNR, MDH, and MPCA would work together to determine the need for consumption advisories

depending on the result of this monitoring work.

 Gap: Despite efforts to phase some PFAS, such as PFOA and PFOS, out of production, discharges of

these PFAS and others continue.

 Opportunity: MPCA could consider the need for a statewide water quality standard for PFAS,

prioritizing PFAS that are especially bioaccumulative and toxic to humans.

 After development of a standard, implementation needs to be considered – particularly for

pollutants like PFAS that are difficult to treat and where standards are likely to be very

stringent.

How does this work benefit human health and the environment?

 Understanding PFAS levels in fish and game, providing advice to consumers about safe levels of

consumption, and applying regulations to dischargers to prevent further contamination all contribute

to ensuring that people are not exposed to harmful levels of PFAS.

 Work done to protect human consumers of fish and game has the ancillary benefit to helping to

prevent wildlife exposures.

 Fish consumption is beneficial for our health – regulations on dischargers of bioaccumulative

pollutants like PFOS help encourage consumption of fish by ensuring surface waters used for fish

harvesting are free of harmful levels of toxins.

How does this work benefit Minnesota’s economy?

 The commercial fishing and game industries in Minnesota benefit from work done to ensure fish,

deer, and waterfowl do not accumulate harmful levels of PFAS.

 Tourism related to recreational hunting and fishing also supports some to local economies, which

would benefit from ensuring safe consumption of fish and game.

 Fishing and hunting provide a healthy and inexpensive source of food for many families.

 Preventing adverse physical health outcomes associated with PFAS exposure and preventing negative

mental health outcomes associated with concern over exposure to these compounds is financially

beneficial for families and individuals.

Minnesota’s PFAS Blueprint • February 2021

Background

Hunting and fishing are cherished activities in Minnesota, with long-standing cultural significance for

many populations. Nearly all of Minnesota is ceded territory, with Tribal nations that pre-date the

establishment of Minnesota retaining hunting, fishing, and gathering rights. Beyond providing

opportunities to engage in cultural heritage, entertainment, and enjoyment of the outdoors, these

activities also provide healthy sources of food for many Minnesotans. In some cases, locally harvested

fish and game are relied on as a key component of a family’s diet. Unfortunately, continued research on

PFAS in fish and wildlife has indicated that some PFAS can accumulate in commonly consumed tissues of

fish and game, potentially to levels causing exposure concerns for those consuming the meat.

Ensuring that the fish and game harvested in Minnesota are safe for consumption is an important goal

of MDH, MPCA and DNR. Most work has focused on safe consumption of fish. The Fish Contaminant

Monitoring Program (FCMP) is an inter-agency program that collects fish from lakes and rivers

throughout Minnesota with the cooperation of the DNR Fisheries and MPCA Biomonitoring teams. The

primary role of the program has been to analyze fish tissue for levels of mercury and polychlorinated

biphenyls (PCBs), but Minnesota has provided and received occasional funding that has enabled

additional analysis for PFAS, coordinated through this program. The data gathered support the MDH’s

Fish Consumption Guidelines and MPCA’s development of water quality standards for aquatic

consumption. In addition to fish monitoring, DNR can conduct additional ad hoc monitoring of animals

like deer by working with hunters in areas with known contamination, as funding and capacity allows.

These monitoring projects provide the basis for any issuance of guidance or regulation by MDH or

MPCA.

Risks to fish and game consumers from PFAS pollution

Though there is much still unknown about the health effects associated with PFAS, health assessments

conducted by MDH indicate that toxic effects can potentially occur after exposure to low levels of PFAS

like PFOS, PFOA and PFHxS. Additionally, early work conducted by MPCA to understand PFAS levels in

fish indicate that some PFAS accumulate to high concentrations in edible portions of fish tissues.

Ongoing work in states like Michigan and Wisconsin indicate that some PFAS similarly accumulate in the

organs and tissues of deer, and research at sites with contaminated surface water in Australia resulted

in consumption advice for many commonly consumed species, including waterfowl.

Work is currently underway at the EPA and at Minnesota agencies to gain a better understanding of

PFAS accumulation in fish and game and where there may be risks to consumers from this exposure.

Overall, evidence collected by Minnesota agencies and other researchers indicate that there are several

avenues for PFAS to make their way into commonly consumed fish and game. Studies of exposure to

bioaccumulative PFAS (such as PFOS) have indicated that in scenarios where an individual is consuming

fish and game that have been significantly impacted by PFAS releases, fish consumption and game

consumption can be the most significant source of overall exposure.

Whether or not these levels of

PFAS in game are potentially hazardous to human health depends on individual consumption habits, if

the person exposed is at a particularly sensitive life stage, and if the person is harvesting from a region

proximal to a PFAS source.

Augustsson, A., Lennqvist, T., Osbeck, C.M.G., Tibbin, P., Glynn, A., Nguyen, M.A., Westberg, E., & Vestergren, W. (2021).

Consumption of freshwater fish: a variable but significant risk factor for PFOS exposure. Environmental research. 192 (2021)

110264. https://doi.org/10.1016/j.envres.2020.110284

European Food Safety Authority. (2011). Results of the monitoring of perfluoroalkylated substances in food in the period

2000-2009. EFSA Journal. 9(2). https://doi.org/10.2903/j.efsa.2011.2016

Minnesota’s PFAS Blueprint • February 2021

Role of guidance and regulation related to ensuring safe consumption of fish and game

In Minnesota, the DNR, MPCA, and MDH collaborate to conduct research on PFAS levels in fish and

game, develop consumption guidelines, communicate with fishers and hunters, and regulate PFAS

emissions such that advice to limit fish consumption is not needed in the future. MDH guidance for

eating fish contaminated with PFOS are based on the Great Lakes Consortium for Fish Consumption

Advisories Best Practice for Perfluorooctane Sulfonate (PFOS) Guidelines. The best practice aims to result

in consistent advice across states in the Great Lakes region and takes into account both the risks and

benefits of eating fish.

The first step in addressing potential health risks from PFAS in fish and game is monitoring to

understand what levels of PFAS exist in these animals. The agencies, working through the FCMP, have

conducted analysis for PFAS in fish. Though this research has been crucial to advancing the knowledge of

potentials risks to fish consumers from PFAS exposure, some of these data are now out of date and are

likely not reflective of current PFAS levels. Once a database of PFAS levels is established, the MDH

provides consumption advice to consumers if needed and DNR helps communicate that information. To

date, MDH has issued fish consumption advice based on PFOS for several waterbodies. Deer monitoring

is in the early stages – it is not clear if consumption advice for deer will be warranted once data from an

ongoing pilot deer monitoring are analyzed. The consumption guidance and communication efforts by

MDH and DNR are crucial for educating consumers, especially those who are pregnant or breast-feeding

infants, about potential risks associated with exposure to PFAS.

In addition to issuing guidance, Minnesota also has opportunities to apply regulations that would reduce

(and prevent) the need for restrictive consumption advice in the future. When it comes to fish

consumption, MPCA has the regulatory authority under the CWA to enact either site-specific water

quality criteria or statewide water quality standards protective of those consuming fish from Minnesota

waterways. MPCA also has the authority to derive standards that would be protective of consumers of

aquatic-dependent wildlife like ducks and geese, should those paths for exposure be the most impactful.

MPCA has already issued site-specific criteria protective of fish consumers in several East Metro

waterbodies known to be contaminated with PFAS. MPCA is also considering the benefits that would

come from developing a statewide water quality standard for PFAS that would be protective of fish and

game consumers, including those who rely on harvesting and consuming fish and game for subsistence

or cultural heritage. Finally, MPCA could develop regulations on air emissions of PFAS that could cause

fish to be contaminated with bioaccumulative PFAS. For example, in the past, air emission reductions for

mercury were achieved using the implementation of TMDL approaches under the CWA standards.

Though discussion of regulatory standards for surface water are included in this issue paper below,

discussion of opportunities to reduce PFAS loading to surface water from air emissions are included in

the air issue paper.

There are many potential sources of PFAS to wildlife like fish and game. Some of these sources are

considered “point sources” that could theoretically be controlled with permits of releases to air and

water. Other PFAS sources are more diffuse, such as PFAS plumes originating from spilled PFAS-

containing firefighting foam, land-applied biosolids with high PFAS concentrations, or atmospheric

deposition of PFAS from far-away sources. Overall, controlling PFAS emissions is challenging due to the

widespread use of PFAS products in consumer goods and industry – it is possible that regulatory

standards on water and air emissions of PFAS will not entirely prevent the need for consumption advice

for fish or game moving forward.

EPA. (n.d.). Impaired Waters and Mercury. https://www.epa.gov/tmdl/impaired-waters-and-mercury

Minnesota’s PFAS Blueprint • February 2021

Past and ongoing efforts

The following sections describe the completed and ongoing work related to ensuring safe consumption

fish and game in Minnesota. Ongoing work is primarily focused on monitoring for PFAS in fish and game,

but the expense of PFAS analysis has limited the extent of this work. Additional work is ongoing to

establish PFAS cleanup goals protective of fish consumers and to issue fish consumption advice when

levels are observed in exceedance of the statewide fish consumption guidelines for PFOS.

Monitoring

Pilot monitoring of PFAS in deer

Deer and other wild game in Minnesota have the potential to bioaccumulate PFAS to a degree that

could result in higher exposures to Minnesotans who frequently consume them. Recent efforts to

monitor deer in Wisconsin and Michigan near areas of known surface water contamination have

resulted in the respective DNRs issuing deer consumption advice for either deer liver or, in some cases,

consumption of any deer tissue. After observing the results of these monitoring efforts in Wisconsin and

Michigan, Minnesota’s DNR initiated a deer monitoring pilot study in two areas in Minnesota with

known PFAS contamination of surface water: near the Duluth airport and the East Metro. Starting in

September 2020, Minnesota DNR is collecting liver and muscle tissues from 60 harvested deer that were

either hunted or hit by cars within or near (a five-mile radius) the two areas where PFAS are known to

be impacting surface water. The DNR is reaching out to hunters in these areas directly and ask them to

voluntarily submit liver and muscle tissue samples from their harvested deer for testing purposes.

Additionally, DNR is partnering with local road crews to collect samples from deer hit by cars in the East

Metro region. Out of convenience and to broaden the study sample, the DNR may additionally test

samples from deer taken during population control activities, including up to 30 deer from the Camp

Ripley military facility. Deer harvested at Camp Ripley are frequently used by the DNR for research

because data is relatively easy to collect. The level of PFAS in the environment at Camp Ripley is not

known. Once the samples are collected and analytical results are finalized, DNR will work with MPCA

and MDH to determine if additional deer monitoring or deer consumption guidance are warranted.

Work status: ongoing

Leaders: DNR Wildlife Health. Partners: MDH Environmental Health and MPCA Environmental

Analysis and Outcomes.

Benefits: This project will directly benefit hunters in Minnesota by ensuring that deer harvested are

safe for consumption. Additionally, given that the science of PFAS accumulation in deer is

understudied, this effort will expand the understanding of PFAS accumulation in terrestrial

ecosystems.

Challenges: PFAS analysis is expensive, which limits the number of samples that can feasibly be

analyzed as part of this pilot project. Because samples from deer carcasses are being voluntarily

collected from hunters, it may not be possible to identify the precise location where the deer was

killed, and targeted sampling of deer in very close radius (< 1 mile) to surface water contamination is

not possible. This may hamper DNR’s understanding of the roaming radius for deer that may be

impacted by PFAS exposure. Additionally, it is not known if the concentration of PFAS in deer tissue

is dependent on factors such as the age or sex of the deer. Hunters are encouraged to submit incisor

tooth samples from deer for aging purposes to account for the issue of age on accumulation of

PFAS.

Minnesota’s PFAS Blueprint • February 2021

Resources: The pilot monitoring effort requires $43,000 in funding for PFAS analysis. Because most

PFAS are known to accumulate in livers at greater concentrations than the rest of the body like

muscle, if PFAS results in the liver of a given deer sample are non-detectable, the muscle of the

animal will not be tested. This could reduce the overall analytical costs associated with the project.

Sample collection and communication with hunters requires the time of several DNR staff.

Advice

Providing fish consumption advice for PFOS and conducting outreach and education

Using FCMP data for mercury, PCBs, and PFOS, MDH develops science-based fish consumption

guidelines that encourage people to eat fish while keeping their exposure to contaminants in fish below

a level that may cause adverse health effects. The developing fetus, children, and people who eat a lot

of fish that are high in contaminants are most likely to be harmed from exposure to contaminants in

fish. Fish consumption guidelines for PFOS were developed following protocols developed by the Great

Lakes Consortium for Fish Consumption Advisories and risk assessment methods developed by the

EPA.

The following fish consumption advisory levels were derived:

Table 4. PFOS fish consumption advisory levels.

Level of PFOS in fish fillet (ppb)

Meal frequency

<= 10

Unrestricted

>10-20

2 meals/week

>20-50

1 meal/week

>50-200

1 meal/month

>200

DO NOT EAT

MDH provides statewide Safe-Eating Guidelines developed based on mercury and PCBs in fish statewide

and waterbody specific Safe-Eating Guidelines where advice for eating fish from specific waters and for

specific species are more restrictive than the Statewide Guidelines based on consideration of levels of

mercury, PCBs, and PFOS measured in fish fillets.

Fish harvest – how much a waterbody is used for

fishing for consumption rather than catch and release – is a factor considered by FCMP when selecting

lakes and rivers for fish collection, analysis, and considerations of guidance. For example, FCMP receives

input from DNR about waters fished and species harvested by the Hmong community. MDH also shares

data and consults with tribes on methods for determining fish consumption guidelines.

Higher levels of PFOS have been found in fish from some waters in Minnesota, including several

waterbodies in the Twin Cities Metro. Based on PFOS levels measured in fish, MDH recommended not

eating fish from Lake Elmo in Washington County. This Do Not Eat advice has been extended to lakes

and streams in the Project 1007 storm water drainage area, also in the East Metro Area of the Twin

Cities, with PFOS measured in the water at levels similar to or higher than Lake Elmo. MDH concluded

that fish in these waters are likely to have PFOS concentrations as high or higher than in those in Lake

MDH. (n.d.). Great Lakes Consortium for Fish Consumption Advisories.

https://www.health.state.mn.us/communities/environment/fish/consortium/index.html

Great Lakes Sport Fish Advisory Task Force (1993). Protocol for a Uniform Great Lakes Sport Fish Consumption Advisory.

Retrieved from: Protocol for a Uniform Great Lakes Sports Fish Consumption Advisory (PDF)

Great Lakes Consortium for Fish Consumption Advisories. (2019). Best Practice for Perfluorooctane Sulfonate (PFOS)

Guidelines. Retrieved from: Best Practice for Perfluorooctane Sulfonate (PFOS) Guidelines (PDF)

EPA (n.d.) Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories Documents.

https://www.epa.gov/fish-tech/guidance-assessing-chemical-contaminant-data-use-fish-advisories-documents

MDH. (n.d.) Fish Consumption Guidance. Retrieved from:

https://www.health.state.mn.us/communities/environment/fish/index.html#waterbody

Minnesota’s PFAS Blueprint • February 2021

Elmo. The waters are: Raleigh Creek, Eagle Point Lake, Horseshoe Lake, Tartan Pond, Rest Area Pond,

and West Lakeland Ponds.

It is important that fish consumption guidance is communicated to the public. Safe-Eating Guidelines for

fish are communicated using a variety of dissemination pathways. Information about the Guidelines is

available in printed brochures, on the MDH and DNR websites, DNR Fishing Regulations, and through

presentations at meetings and community gatherings. Outreach efforts are particularly directed toward

women who are or may become pregnant, children, and people who eat a lot of fish. MDH also works to

provide information to healthcare providers and others who may be in contact with these higher-risk

groups. MDH typically issues a news release when updated information is available. In addition to

highlighting revised guidelines and materials, these announcements include information on new or

important issues related to the fish consumption program. Through these news releases, MDH tries to

elicit media coverage (newspaper, radio and TV) to increase public awareness. MDH specifically requests

that local public health agencies; local and state Women, Infants, and Children programs; and health

care providers, including the major Health Maintenance Organizations in Minnesota distribute

educational materials and discuss fish consumption with their clients. Other organizations that distribute

MDH’s printed brochures include local and state parks, environmental organizations, retailers, and other

state agencies.

Work status: ongoing

Leaders: MDH Environmental Health Division. Partners: Interagency Fish Contaminant Monitoring

Program (MDH, DNR and MPCA), Great Lakes Consortium for Fish Consumption Advisories

(Consortium membership includes representatives from Indiana, Illinois, Michigan, Minnesota, New

York, Ohio, Pennsylvania, Wisconsin, the Great Lakes Indian Fish and Wildlife Commission, and the

Ontario Ministry of the Environment and Climate Change), MDH WIC, Local Public Health, Health

care providers in Minnesota, DNR State Parks, HealthPartners Institute.

Benefits: MDH Safe-Eating Guidelines are developed to help consumers minimize their exposure to

contaminants in fish while promoting the health benefits of eating fish. Working with neighboring

states increases the likelihood of compliance with voluntary fish consumption guidance because

there are consistent messages across the region. By communicating PFOS Safe-Eating Guidelines

through various media and targeting several audiences, MDH increases the likelihood that the public

is aware of the guidance and understands the relative benefits and risks of eating certain types of

fish or fish collected in various locations. These outreach efforts enable the public to make choices

about which fish to eat and how often.

Challenges: The PFOS guidelines are developed to reduce exposure, but they are not a solution to

the problem of contamination of PFAS in fish. Additional funding for PFAS fish sampling and analysis

would identify which fish species and at which locations warrant PFOS-based fish consumption

guidance.

PFAS bioaccumulate in fish with different patterns than are seen for PCBs and mercury. This means

that the species of fish with the highest concentrations of mercury or PCBs may not be the same fish

with high levels of PFOS or other bioaccumulative PFAS. More research is needed to understand

which fish species accumulate the most PFAS so that these species can be included in monitoring.

Additionally, there are limited data on PFAS levels in purchased fish, which limits the ability to derive

statewide fish consumption guidance for PFOS and other bioaccumulative PFAS. Finally, there are

limited toxicity assessments for PFAS, and some PFAS known to accumulate in fish do not have

assessments available.

There are still many unknowns about which fish are likely to accumulate PFOS or other PFAS.

Current trends indicate that the species of fish accumulating PFAS are not necessarily the predator

Minnesota’s PFAS Blueprint • February 2021

fish that are likely to accumulate other toxicants of concern like PCBs and mercury. For this reason,

messaging around recommended fish intakes is challenging.

Anticipated resource needs: Continued sampling and analysis of Minnesota fish for PFAS would be

needed to continue assessing the need for fish consumption guidance statewide. The Fish

Contaminant Monitoring Program estimates that this expanded PFAS monitoring effort would

require $640,000 per biennium of additional funding. The agencies might also require extra staff if

additional fish are collected.

Regulation

Deriving site-specific water quality criteria for PFAS protective of fish consumption

Water Quality Criteria (WQC) are site-specific surface water values that are applied to address pollution

in areas of known surface water contamination. These WQC are different than WQS in that they do not

apply to the entire state, only to waterbodies explicitly included in the criteria. WQC are developed

based on methods and authorities in state statute and the federal CWA (see Minn. R. ch. 7050).

The MPCA Remediation program is managing sites with PFAS surface water contamination and

requested WQC for PFAS be derived for impacted waters to inform cleanup efforts. In October 2020,

MPCA released a new PFOS WQC that applied to targeted waterbodies including Lake Elmo and

connected waterbodies in Washington County. When deriving WQC for those sites, MPCA also took the

opportunity to update existing WQC for PFOS elsewhere in the state (Bde Maka Ska, and Pool 2 of the

Mississippi River). MPCA prioritized deriving a PFOS WQC because PFOS has the highest bioaccumulation

potential in fish compared to the other PFAS with health-based guidance values available. This high

propensity of PFOS to accumulate in fish means that the largest pathway of exposure for those

interacting with PFOS-contaminated water is through consuming fish caught in that waterbody. MPCA is

in the process of developing WQC for other PFAS found in surface waters in these impacted

waterbodies.

The site-specific WQC for PFOS required an assessment of PFOS toxicity and exposure from fish tissue.

The criteria incorporate a model-based toxicological and exposure approach similar to that used by the

MDH to develop drinking water guidance. The criteria are based on protecting the populations most

vulnerable to PFOS toxicity, which are the developing fetuses and newborn infants being exposed to

PFOS through the placenta during pregnancy and through breastmilk in early life. In selecting the fish

consumption values for the criteria, MPCA reviewed new fish consumption survey datasets from the

MDH, Great Lakes Consortium for Fish Consumption Advisories, and other regional and national studies

relevant to the amount and types of freshwater-caught fish consumed by women of childbearing age

(ages 15 to 50). Because PFOS and other PFAS are developmental toxicants, characterizing potential

exposure to this subgroup of fish consumers from PFOS is very important. The interim fish consumption

rate for women of childbearing age used in this PFOS WQC is over twice the default rate for adults who

eat freshwater-caught fish and is based on a study led by MDH called, “Fish are Important for Superior

Health” (FISH).

The new WQC for PFOS can be expressed either as a fish tissue concentration or as a water

concentration. For fish tissue, the WQC is a maximum 0.37 nanograms PFOS per gram (ng/g). The

corresponding WQC for water is a maximum 0.05 nanograms per liter (ng/L). The goal of these WQC is

to reduce the levels of PFOS in water so that freshwater fish consumption does not contribute to a

person’s total exposure to PFOS, resulting in body burdens of PFOS greater than those associated with

health effects.

MDH. (n.d.). Great Lakes Restoration Initiative Grants. Retrieved from:

https://www.health.state.mn.us/communities/environment/fish/consortium/glrigrant.html#keyfindings

Minnesota’s PFAS Blueprint • February 2021

Work status: completed for PFOS, ongoing for other PFAS

Leader: MPCA Water Quality Standards Unit. Partners: MPCA Water Assessment and MDH

Environmental Surveillance and Assessment.

Benefits: PFOS WQC are based on protecting people’s health from the presence of this toxic

pollutant in Minnesota’s surface waters and fish. The criteria provide numeric targets for MPCA

programs to use in remediation cleanup, wastewater permitting, and other environmental

protection authorities. Reductions of PFOS have already been documented in some surface waters

due to national restrictions by EPA on some PFAS, including PFOS, and ongoing remediation

activities. Any efforts to reduce PFOS pollution also benefit fish and wildlife.

Challenges: The PFOS WQC consist of an applicable fish-tissue concentration and surface water

concentration. These values are very low and require the use of the most recently developed

analytical methods to assess. The MPCA has a contract with SGS AXYS Analytical, who recently

lowered reporting limits for PFOS and a few other PFAS. The fish-tissue WQC of 0.37 ng/g can be

accurately quantified by SGS AXYS, but the water concentration of 0.05 ng/L cannot. The MPCA’s

Effluent Limit Unit is working with the Environmental Data Quality Unit to develop guidance for

permitees related to these analytical issues.

Minnesota’s impaired waters or 303(d) list contains 10 existing impairments for PFAS. These include

impairments based on MDH’s fish consumption advice (an approach MPCA no longer uses for listing

waters that are impaired for consumption of fish tissue) and on site-specific water quality criteria.

There are a large number of new surface water and fish-tissue PFOS datasets available since the last

time PFAS was assessed statewide, and the new site-specific WQC is much more stringent than prior

values. The MPCA is continuing to work on identifying the best path forward in assessing and listing

impaired waters for PFAS. MPCA is considering the long-term need for a statewide PFOS WQS,

which would result in statewide assessment for impaired waters listing wherever PFOS fish tissue

data were available.

Resources: The development of the PFOS WQC took an MPCA staff person approximately two years

and involved the support of several other technical staff at MPCA and MDH. This effort was only

possible because MDH had already conducted a human health assessment for PFOS containing

toxicity values and a serum model for understanding PFOS transfer to infants. Currently, the Water

Quality Standards Unit is developing new site-specific WQC for PFOA (which would allow for

additional updates to existing WQC for Bde Maka Ska and Pool 2), PFBA, PFHxS, and PFBS. These

PFAS also have MDH toxicological values and health based guidance for drinking water that are

relevant for this work. The development of the new interim fish consumption rate for women of

childbearing age took almost a year to obtain and review survey datasets; this rate needs further

review and consultation with Tribes and other subsistence fishing communities before adopting into

rule

Gaps and opportunities

Several gaps remain in the scientific understanding of PFAS exposure from fish and game consumption

and in the regulatory and advisory programs that ensure safe consumption for Minnesotans. PFAS are a

diverse class of compounds with differences in toxicity, bioaccumulation potential, and environmental

fate and transport. Though there are trends in toxicity and bioaccumulation patterns amongst various

PFAS, such as the trend that longer chain PFAS tend to accumulate more readily in fish and wildlife,

there are also exceptions to these trends. Much is still unknown about how factors like species type,

water chemistry, and age of the organism influence PFAS levels in that sample. Ongoing fish and game

monitoring will help fill this gap and prioritize risk assessment for PFAS.

Minnesota’s PFAS Blueprint • February 2021

Another gap is in developing a broader and up-to-date understanding of PFAS levels in commonly

consumed fish. Expanding the existing Interagency Fish Contaminant Monitoring Program to regularly

include PFAS sampling (in addition to the existing PCB and mercury sampling) would greatly improve the

overall understanding of PFAS exposure from fish consumption, supporting the updates of statewide fish

consumption guidelines and site-specific fish consumption guidelines. This work would have the additional

benefits of improving understanding of locations with PFAS sources that may be currently unknown and

improving the overall knowledge base about which fish are most likely to accumulate PFAS.

Finally, there are gaps in the regulatory structures that control PFAS loading to waterbodies. Developing

a statewide WQS for bioaccumulative PFAS would prevent ongoing discharges of PFAS at levels that

would cause PFAS to accumulate beyond safe levels in fish, and possibly also waterfowl and deer tissues.

This effort, along with similar efforts to reduce PFAS emissions to the air, would gradually reduce the

need for additional consumption guidance for fish and other game.

Monitoring

Conduct routine PFAS monitoring in fish

The interagency FCMP collects fish from lakes and rivers throughout Minnesota with the cooperation of

DNR Fisheries and MPCA biomonitoring programs. The primary role of the program has been to analyze

fish tissue for levels of mercury and PCBs. However, since the realization that PFAS may be

bioaccumulating in Minnesota fish, the group has conducted some PFAS sampling as part of the

monitoring program. Since PFAS testing began in Minnesota’s lakes and streams in 2004, fish have been

collected for PFAS from 178 lakes and 12 rivers, many of which have led to fish consumption advisories

based on observed levels of PFOS in fish tissue. In the recent 2018 survey 73 waterways were tested and

94.5% of the waterways (n = 69) had at least one fish with detectable PFOS concentration in the fillet; 43

of those waters had been tested previously and all but one continued to have detectable PFOS

concentrations. Monitoring has shown that in instances where sources of PFOS to a waterbody declined

and past pollution migrated downstream, there are subsequent declines in fish tissue PFOS

concentrations.

PFAS contamination in fish appears to be pervasive across Minnesota: 84% of the Metro lakes and 22%

of the Non-metro lakes sampled to date had fish with detectable levels of PFOS. Of the lakes with a

known PFAS source nearby, all lakes had fish with detectable levels of PFOS, in both Metro and Non-

metro waters. Sampling in Non-metro waters has been mostly convenience survey sampling, while

sampling in Metro waters was more targeted at likely but not “known” PFAS sources. Metro lakes had

3.8 times the risk of having fish with detectable levels of PFOS compared to Non-metro lakes. Non-

metro lakes near a PFAS source had 5.6 times the risk of having fish with detectable levels of PFOS

compared to lakes not near a known PFAS source.

Work status: ongoing – additional funding proposed to fill monitoring gaps

Leaders: The Interagency FCMP (including representatives from MPCA, DNR, MDA, and MDH).

Benefits: This ongoing project provides necessary updated fish contaminant data for the impaired

waters inventory (MPCA) and fish consumption guidance (MDH). The project is efficient and cost-

effective because it relies on the existing structure of the Interagency FCMP for planning, collection,

laboratory testing, data management, and data analysis.

Challenges: PFAS laboratory analysis must be done through a master contract with a private

laboratory, unlike mercury and PCBs analyses which can be performed by MDA Environmental

Laboratory. The high cost of PFAS analysis (~$400/sample) requires supplemental funding, which has

not been consistent or predictable. Given the limited funding and uncertainty of PFAS sources,

selecting lakes and streams for first-time testing is an ongoing challenge. PFAS contamination in fish

Minnesota’s PFAS Blueprint • February 2021

does not follow the patterns seen for other contaminants, making it challenging to know how often

to resample known contaminated sites.

Anticipated resource needs: To address the need for expanded PFAS fish monitoring, the Interagency

FCMP propose that PFAS become a routine analysis along with mercury and PCBs. It is estimated that

this effort would require $640,000 per biennium of additional funding for extra analysis of fish that are

already collected. It might also require extra staff if additional fish are collected.

Regulation

Develop statewide water quality standards for PFAS

The MPCA sets WQS to protect multiple beneficial uses – including domestic consumption (drinking

water), aquatic consumption (human consumption of fish and shellfish), aquatic life (a healthy

assemblage of aquatic biota) and wildlife (drinking water for wildlife). Preliminary data from monitoring

PFAS in fish indicate that several PFAS – and particularly PFOS - bioaccumulate in fish tissue at levels that

may be a concern for human consumption or the health of the aquatic ecosystem. Implementing

statewide WQS for PFAS would provide regulatory basis for reducing PFAS loading to aquatic

ecosystems, thereby removing the need for fish consumption guidance or other restrictions on the

beneficial uses of waterbodies in the state.

Every three years, the CWA mandates that MPCA review existing WQS and propose revisions or

additions as needed. The MPCA’s Water Quality Standards Unit is currently undertaking the Triennial

Standards Review process to determine if the development of a statewide PFAS standard will be placed

on the MPCA’s 2021 – 2024 water quality standards work plan. If MPCA determines there is a need to

develop new PFAS WQS for any of these beneficial uses, the development of these numeric standards

and adopting them into rule would be a multi-year process with several steps including economic

analysis; outreach to potentially impacted partners, stakeholders, and Minnesotans; public comment

and process steps (stipulated by the Administrative Procedures Act); and EPA approval. If the EPA does

not publish recommended CWA criteria for PFAS and MPCA needs to develop standards itself, the

standards will also require external peer review, which adds additional time and review to the process.

See the Limiting PFAS Exposure from Drinking Water Issue Paper for discussion on developing WQSs

applicable to waterbodies used as sources for drinking water and the Managing PFAS in Waste Issue

Paper for a general discussion of WQSs in the context of waste facilities.

Work status: under consideration

Leader: MPCA Water Quality Standards Unit. Partners: MPCA Water Assessment and MDH Health,

Environmental Surveillance, and Assessment Section.

Benefits: Water Quality Standards are regulatory values that are important tools to prevent and

abate toxic pollutants affecting the beneficial uses of water resources. PFOS and other PFAS are

pollutants known to occur in Minnesota surface waters. Their presence results from many ongoing

water discharges and air emissions of PFAS. The levels of PFAS in some of Minnesota’s waterbodies

are causing some municipalities to install treatment of drinking water for PFAS, at great expense to

taxpayers. Levels of PFAS are also impacting fish, triggering the need for fish consumption guidance,

up to and including “do not eat” for fish at popular fishing locations. Minnesota’s DNR is currently

investigating potential uptake of PFAS from surface water to game people eat, like deer. These

damages to natural resources hurt all Minnesotans, but especially those who rely on locally caught

fish and game as a healthy source of protein for themselves and their families. Statewide WQS

would provide transparent regulatory values and allow for the implementation of all related water

quality programs – including effluent limits, assessment and impaired waters listings. These related

actions would reduce ongoing PFAS releases to the environment and support continued progress on

reducing the presence and concentration of these toxic pollutants in already impacted regions.

Minnesota’s PFAS Blueprint • February 2021

Challenges: WQS rulemaking involves significant agency staff resources. The benefits and costs of

implementing WQS into statewide permitting and impaired waters listing would need to be

evaluated. Rulemaking for PFAS WQS is especially complex because PFAS is a family of compounds

consisting of thousands of known structures. Given the current state of knowledge regarding PFAS

toxicity, MPCA would likely only be able to adopt WQS for human health based beneficial uses

(drinking water and aquatic consumption) for those PFAS with health assessments completed by

MDH or another risk assessment organization like the EPA or CDC. Additionally, research into

appropriate fish consumption rates would be needed, including outreach to high fish consuming

communities. Considerations of fish-eating wildlife and water to terrestrial organism impacts (like

deer-drinking contaminated surface water) could also be considered. This effort would require a

team of staff scientists and program managers with various areas of expertise.

Resources: Adopting WQS requires support from the Governor’s Office and other state agencies, in

addition to time dedicated by many MPCA staff across multiple units.

Overview of intersectional issues

 Pollution prevention: Reducing PFAS pollution at the source places the burden with the polluters

rather than receptors like consumers of locally harvested fish and game. The breadth of PFAS in

use in products and industry and ongoing registration of new PFAS means that environmental

monitoring and risk assessment cannot keep up. See the Preventing PFAS Pollution Issue Paper for

actions related to reducing the overall production and emission of PFAS products.

 Quantifying PFAS toxicity:  Having an understanding of the potential health impacts of PFAS

exposure is key in ensuring exposure stays below “safe” thresholds and communicating with the

public. Health-based guidance values, however, require data on toxicity and exposure that are

not available for the vast majority of all the PFAS found in the environment. See the Quantifying

PFAS risks to Human Health issue paper for more information on challenges stemming from

PFAS toxicity data limitations. 

 Protecting Minnesota wildlife: The limited data available for a small number of PFAS currently

indicate that health-based values protecting humans from PFAS exposure from drinking water

and fish consumption are more stringent than benchmarks protective of wildlife – therefore,

protecting surface water for accumulation of PFAS in commonly consumed fish will also protect

those fish and wildlife against toxic effects of those PFAS. However, ongoing review of wildlife

research is needed to ensure that research continues support that conclusion, and that these

conclusions also hold for other PFAS that are currently unstudied.

 Developing and expanding access to analytical methods: Analytical methods for PFAS are

expensive and time-intensive to run and include only a subset of all PFAS that may be occurring

in fish and game. Increased access to non-targeted analysis and cheaper screening-level PFAS

methods would be beneficial for protecting consumers of fish and game – see the Measuring

PFAS Effectively and Consistently Issue Paper for more information on the costs and challenges

associated with measuring PFAS in biological matrixes. 

 Managing PFAS in waste: Although waste facilities like landfills, composting facilities, and

wastewater treatment plants are generally not sources of PFAS, they serve as conduits of PFAS

to the environment from PFAS sources like industrial PFAS users or producers and consumer of

PFAS-containing products. In some instances, PFAS concentrations from waste streams may

result in levels of bioaccumulative PFAS like PFOS in surface water or soil that could lead to

human health concerns for consumers of fish and game. Care is needed to capture PFAS

pollution before it reaches waste facilities so that the operators of these facilities do not bear

the full financial burden of mitigating PFAS emissions from other polluters.

Minnesota’s PFAS Blueprint • February 2021

Limiting PFAS

exposure from food

Background

 Minnesotans should have confidence that their food is free from harmful toxins.

 Data collected by the Food and Drug Administration (FDA) and others indicate that widespread PFAS

contamination of food products is not occurring in the US. However, if the environment where food

is grown or raised has PFAS contamination, this PFAS can accumulate into vegetables, grains, meat,

and dairy products.

 Generally, foods with the highest PFAS concentrations are fish and game (especially organ meat)

harvested from areas with PFAS contamination. For this reason, there is a separate issue paper on

ensuring safe consumption of fish and game harvested in Minnesota. This paper focuses on PFAS

in food systems broadly.

 There is a wide range of potential exposure to PFAS from food based on individual consumption

habits and geographic proximity to PFAS sources.

 There are multiple avenues by which PFAS can contaminate food. PFAS can accumulate in produce and

livestock from contaminated water, biosolids, air, soil, or animal feed or migrate into food from PFAS-

coated cookware and food packaging.

 Though most produce, meat, and dairy does not contain detectible levels of PFAS, there have been

several examples of farms around the US forced to shut down operations after realizing that PFAS

contamination on their property was resulting in accumulation in food.

 FDA’s regulation of food contact materials considers direct exposure due to migration of the PFAS

from the food contact material to the food – it does not consider risks associated with

environmental releases (including releases to farmlands) following disposal of such food contact

materials.

 After public concerns over exposure to the PFAS 6:2 fluorotelomer alcohol FTOH, FDA recently negotiated a

phase-out of its use in food packaging.

 Containers used to store and transport pesticides can contain PFAS. Pesticide active ingredients

and inert materials used in Minnesota are not known to contain PFAS.

What is Minnesota doing now?

 Assessed risks from produce grown in home gardens

 MPCA partnered with MDH to conduct a study of PFAS levels in exterior tap water, garden soil, and

garden produce of homes in the East Metro to determine the extent to which current or past use

of contaminated water for irrigation influenced levels of PFAS in garden soil and homegrown

produce. This study concluded that there were no health risks associated with consuming

homegrown produce.

 Investigated the presence of PFAS in pesticides used in Minnesota

 In 2007, the MDA examined pesticide active and inert ingredients as a potential source of PFAS.

Based on the information received from the EPA and the Minnesota pesticide registration

database, MDA concluded that pesticides are not a significant source of PFAS. MDA was not aware

of and did not consider any potential contribution from the pesticide containers.

Limiting PFAS exposure from food

Summary

Minnesota’s PFAS Blueprint • February 2021

What are remaining gaps and opportunities for action?

 Gap: Recent research shows that high levels of PFOS in milk may be possible if avenues of exposure to

PFOS for dairy farms, and the animals on those farms, are not controlled. Because this is a relatively

new discovery, livestock producers and associated industry stakeholders are not always knowledgeable

about PFAS, including PFOS, and the potential paths of exposure to farms.

 Opportunity: MDA could work with MPCA to identify and limit PFOS pollution in agricultural areas

so that impacts to farms are limited. Voluntary free testing of feed, biosolids, or other potential

upstream PFAS sources could encourage farmers to help proactively identify potential pathways

for contamination. The goals of this work are not regulatory, but rather to expand knowledge and

identify areas for future interventions that would protect farmers and food systems.

 Gap: While land application of biosolids has benefits for farming, land application has potential to

contribute PFAS to groundwater, soil, surface water, crops, and, in some cases, livestock. These gaps in

knowledge about PFAS fate and transport in biosolids make it difficult to proactively manage biosolids

in a way that prevents contamination of food systems and protects farmers against the financial

burdens associated with PFAS contamination.

 Opportunity: With funding, MPCA could implement an existing proposal to 1) to evaluate and

characterize PFAS concentrations in land‐applied biosolids; leaching from those wastes; and

subsequent movement of PFAS into water and food, and 2) to analyze alternative disposal and

treatment options.

 Gap: Many studies have indicated that food packing is a source of PFAS exposure through food, but

these products continued to be used around the country.

 Opportunity: FDA has begun working with manufacturers to take voluntary steps to remove some

PFAS from food packaging materials, Congress has banned the use of PFAS in food packaging for

military meals, and many states and international groups have already mandated phase-outs of

PFAS in food packaging. Minnesota could consider legislative action to ban the addition of PFAS to

packaging, leveraging the policy research already completed by the Toxics in Packaging Clearing

House and the existing laws in other states. These considerations could be part of a larger effort to

review PFAS uses in consumer products or could be a standalone effort.

How does this work benefit human health and the environment?

 Collaborating with farmers to understand the ways that PFAS may be incorporated into food and

stopping PFAS loading from other industries to land and water used for agriculture prevents PFAS

concentrations from reaching levels that could result in significant accumulation in food.

 Preventing PFAS exposure from food packaging materials would have the direct benefit of decreasing

overall exposure to PFAS, which lessens the likelihood of adverse health outcomes.

How does this work benefit Minnesota’s economy?

 Protecting agricultural businesses from the financial impacts associated with PFAS contamination

ensures that these businesses do not bear the burden of PFAS pollution caused by other industries.

 Preventing adverse physical health outcomes associated with PFAS exposure and preventing negative

mental health outcomes associated with concern over exposure to these compounds is financially

beneficial for families and individuals.

Minnesota’s PFAS Blueprint • February 2021

Background

Minnesotans should be confident that their food is free of harmful toxins. Understanding potential

human exposure to PFAS from food is complex and requires investigating the multiple ways PFAS gets

into food. Higher levels of PFAS on farmland can result in contaminated food products like produce,

livestock, eggs, and dairy products as PFAS moves from water or soil to accumulate in the plants or

grazing livestock. However, PFAS can also become incorporated into the foods we eat through PFAS

used in food packaging or PFAS used to coat the cooking materials we use to prepare them. Adding to

the complexity of food exposure is the wide variety of PFAS, all of which vary in uptake and sorption

depending on their chemical structures. Studies have indicated that there is a large range of potential

exposure to PFAS from food based on individual consumption habits, differences in geographic

locations, and proximity to PFAS sources that may be impacting the local food production systems.

Unlike some other contaminants of concern in food, such as pesticide residues, PFAS bioaccumulate into

the plant and animal tissue itself and are therefore not removed by washing or cooking.

This issue paper aims to provide background information on how PFAS can make their way into

agricultural products, ongoing efforts to understand PFAS levels in food, and the regulatory structures in

place to control levels of environmental contaminants like PFAS in food products. Next, this document

will discuss the past and ongoing efforts underway at MDA and MPCA to understand potential PFAS

impacts on Minnesota food systems, the gaps in current knowledge and policy, and opportunities to fill

those gaps.

Potential avenues for PFAS to impact food systems

So far, data collected by the FDA indicate that widespread PFAS contamination of food products is not

occurring in the US However, there are several known mechanisms by which PFAS can enter the food

system and potentially contaminate agricultural products; discrete instances of PFAS contamination of

fish, dairy products, meat products, and produce have been observed at farms that were impacted by

localized environmental contamination of PFAS. The following sections describe mechanisms for PFAS to

make their way into foods.

Contaminated water, soil, and feed for livestock

There have been several examples across the country of farms being forced to shut down after PFAS

contamination in water and feed for livestock was found to lead to PFAS accumulation in milk and meat

products. In New Mexico, a dairy farmer was forced to close his farm after finding that groundwater

contamination from PFAS-containing firefighting foam use at a nearby Air Force base resulted in PFOS

contamination of the milk, beef, and crops produced on his property.

In Maine, a farmer was notified

that his drinking water was contaminated with PFOS. As this water was also used for livestock drinking

water, the farmer voluntarily tested the soil on his property, the hay used for feed, the cows’ milk and

both his and his wife blood – all showed elevated levels of PFAS.

Further investigation revealed that

the sources of PFAS to the livestock in this case likely included land-applied biosolids that had been

contaminated with PFAS, land application of bioash and sludge from a local paper mill that likely

included PFAS, and PFAS-contaminated drinking water. After this discovery, Maine set up a screening

FDA. (n.d.). Questions and Answers on PFAS in Food. Retrieved from: https://www.fda.gov/food/chemicals/questions-and-

answers-pfas-food

Linn, A. (2019, February 19). Groundwater contamination devastates a New Mexico dairy – and threatens public health.

Searchlight New Mexico. Retrieved from: https://nmpoliticalreport.com/2019/02/19/groundwater-contamination-devastates-

a-new-mexico-dairy-and-threatens-public-health/

Valdmanis, R. & Schneyer, J. (2019, March 19). The curious case of tainted milk from a Maine dairy farm. Reuters. Retrieved

from: https://www.reuters.com/article/us-usa-dairy-chemicals/the-curious-case-of-tainted-milk-from-a-maine-dairy-farm-

idUSKCN1R01AJ

Minnesota’s PFAS Blueprint • February 2021

program for PFAS in milk sold in the state and developed a health-based screening level for PFOS levels

in milk (210 parts per trillion, equivalent to 210 ng/L). This screening process resulted in the discovery of

another PFAS impacted dairy farm, this time in central Maine, which had levels up to 32,200 ng/L in raw

milk.

Both farms in Maine have been forced to shut down due to the contamination. In Colorado, a

farm near an Air Force base that used PFAS-containing firefighting foam was forced to stop all

agriculture production after finding that PFAS had contaminated every type of food the farmer grew on

the property, including spinach, garlic, and carrots, eggs, pork, and beef.

These are just examples of

farms impacted by PFAS in water, soil, and biosolids that go on to impact produce, livestock feed, and

livestock themselves – it is likely that other farms also have PFAS impacts on their properties but are

currently unaware of the contamination.

Uptake into produce from air, water and soil

In addition to pathways for PFAS to contaminate livestock, it is also important to consider the

mechanisms for PFAS to enter plants. Many PFAS are known to be transferred from soil to plants, with

higher rates generally observed for short-chain PFAS like PFBS and PFBA than for longer-chain PFAS.

However, some PFAS have also been shown to be incorporated into plants from the air.

MDH’s study

of PFAS content in produce grown in home gardens found that water loading of PFBA (calculated as the

PFBA water concentration × minutes of watering/season) correlated to the PFBA concentration in the

produce, indicating plant uptake from water. Much is still unknown about which PFAS are most likely to

accumulate in plants, and which plant species are most likely to absorb PFAS.

Some plant species have

shown such a high affinity for PFAS sorption from soils that there has been discussion of intentionally

using these plants as a tool to remove PFAS and remediate contaminated soils.

Should there be

commonly consumed plants with similar “hyperaccumulating” properties, care should be taken to

ensure that any such plants grown for human or livestock consumption are not planted in an area with

PFAS soil impacts.

Pesticide application

PFAS have, in the past, been used in a small number of pesticides both as the active ingredient to kill the

targeted pests and as inactive parts of the formulation. Recent investigation has also indicated that PFAS

are unintentionally present in at least one pesticide (Anvil 10-10, a pesticide used for mosquito

spraying), which is believed to have been introduced from PFAS-containing packaging materials.

Given the extreme persistence of PFAS, there are concerns about the presence of PFAS in pesticides or

containers that could be used to store and transport pesticides. Pesticides are applied to Minnesota

fields or household lawns to kill insects, weeds, and microorganisms. When pesticide registrants have

Miller, K. (2020, July 24). State investigating ‘very startling’ levels of PFAS chemicals on central Maine dairy farm. Portland

Press Herald. Retrieved from: https://pfascentral.org/news/state-investigating-very-startling-levels-of-pfas-chemicals-on-

central-maine-dairy-farm

Subbaraman, Nidhi. (2019, July, 3). Farmers Losing Everything After ‘Forever Chemicals’ Turned Up In Their Food. BuzzFeed

News. https://pfasproject.com/2019/07/03/farmers-losing-everything-after-forever-chemicals-turned-up-in-their-food/

Wang W., Rhodes, G., Ge, J., Yu, X., & Li, H. (2020). Uptake and Accumulation of Per- and Polyfluoroalkyl Substances in Plants.

Chemosphere. 261 (2020) 127584. https://doi.org/10.1016/j.chemosphere.2020.127584

Jiao X., Shi, Q., & Gan, J. (2020). Uptake, accumulation and metabolism of PFAS in plants and health perspectives: A critical

review. Critical Reviews in Environmental Science and Technology, DOI: 10.1080/10643389.2020.1809219

Huff, D. K., Morris, L.,A., Sutter, L., Costanza, J. & Pennell, K.D. (2020). Accumulation of six PFAS compounds by woody and

herbaceous plants: potential for phytoextraction. International Journal of Phytoremediation, 22 (14) 1538-1550.

https://doi.org/10.1080/15226514.2020.1786004

Abel, D. (2020, Dec 1). Toxic ‘forever chemicals’ found in pesticide used on millions of Mass. Acres when spraying for

mosquitoes. Boston Globe. Retrieved from: https://www.bostonglobe.com/2020/12/01/metro/toxic-forever-chemicals-found-

pesticide-used-millions-mass-acres-when-spraying-mosquitos/

EPA. (n.d.) Per- and Polyfluoroalkyl Substances (PFAS) in Pesticide Packaging. Retrieved from:

https://www.epa.gov/pesticides/pfas-packaging

Minnesota’s PFAS Blueprint • February 2021

registered PFAS as pesticides with the EPA, regulators acknowledged the potential to contaminate

groundwater and surface water and restricted the registered uses. Such pesticides have generally been

limited to residential settings where they were used for applications like for wasp nest or roach control.

One such pesticide is Sulfluramid, which rapidly degrades in the environment to PFOS. Products

containing Sulfluramid were never registered for food or crop use, but were allowed for indoor and

outdoor use in residential buildings. In 2001, EPA negotiated an agreement with Sulfluramid producers

to phase out sales of the product.

Despite efforts to reduce uses of pesticides that contained PFAS as

an active ingredient, the other substances that go into pesticide formulation (often called “inert”

ingredients) do not receive the same level of scrutiny as pesticide active ingredients. When EPA created

a Significant New Use Rule for PFOA and PFOS under TSCA, this rule banned the use of PFOA or PFOS as

inert ingredients in pesticides.

MDA has concluded that other inert ingredients used in Minnesota do

not contain intentionally added PFAS (see the past project titled “Investigated presence of PFAS

additives to pesticides registered for use in Minnesota” on page 102).

Transfer from food contact materials

The FDA regulates the substances used in food contact materials, with the goal of ensuring that these

substances do not pose a risk to human health due to transfer of toxics into food. FDA states: “The

authorization of the use of a food contact substance requires that available data and information

demonstrate that there is a reasonable certainty of no harm for that use. To ensure food contact

substances are safe for their intended use, the FDA conducts a rigorous review of scientific data prior to

their authorization for market entry. This includes reviewing data on migration of the food contact

substance into food, expected consumer exposure to the food contact substance from this and other

uses in food, and potential health impact from this exposure.”

The FDA has approved several PFAS for use in different food contact applications including

manufacturing non-stick cookware coatings. FDA states that because PFAS coatings are made of

molecules that are polymerized and applied to the cookware through a heating process that tightly

binds the polymer coating to the cookware, there is a “negligible” amount of PFAS migrating to food.

Similarly, FDA argues that PFAS used in manufacturing of gaskets that come into contact with food do

not pose a safety risk because they are also made of molecules that are polymerized. FDA has also

approved PFAS uses on paper or paperboard and acknowledges that this PFAS can potentially migrate to

food – however, FDA states that the “rigorous premarket safety review” ensures that the use of PFAS in

food contact applications is safe.

Despite this stance, due to ongoing concerns about potential human

health risks from PFAS authorized for use in food contact papers, FDA negotiated a phase-out of one

PFAS (6:2 fluorotelomer alcohol), subject to the voluntary agreements.

FDA’s regulation of food

contact materials considers direct exposure due to migration of the contaminant from the food contact

material to the food – it does not consider potential environmental contamination and subsequent

contamination of food systems associated with disposal of such food contact materials. (See the

Managing PFAS in Waste Issue Paper.)

EPA. (n.d.). Office of Pesticides. Sulfluramid. Retrieved from:

https://iaspub.epa.gov/apex/pesticides/f?p=CHEMICALSEARCH:31:::NO:1,3,31,7,12,25:P3_XCHEMICAL_ID:3957

Perfluoroalkyl Sulfonates; Significant New Use Rule. 67 FR 72854. 72854-7286. (proposed Dec 2002, final Jan 2003). Retrieved

from: https://www.federalregister.gov/documents/2002/12/09/02-31011/perfluoroalkyl-sulfonates-significant-new-use-rule

FDA. (n.d.). Authorized Uses of PFAS in Food Contact Applications. Retrieved from:

https://www.fda.gov/food/chemicals/authorized-uses-pfas-food-contact-applications

FDA. (n.d.) Questions and Answers on PFAS in Food. Retrieved from: https://www.fda.gov/food/chemicals/questions-and-

answers-pfas-food

FDA. (2020). FDA Announces the Voluntary Phase-Out by Industry of Certain PFAS Used in Food Packaging. Retrieved from:

https://www.fda.gov/food/cfsan-constituent-updates/fda-announces-voluntary-phase-out-industry-certain-pfas-used-food-

packaging

Minnesota’s PFAS Blueprint • February 2021

PFAS monitoring in food

Various government agencies around the globe have recently made efforts to monitor for PFAS in food

and compile publicly available data. Though the US FDA has only conducted a handful of studies of PFAS

in food, the European Food Safety Authority (EFSA) published a comprehensive review on the topic in

2020.

Efforts by both agencies indicate that the food products with the highest concentrations and

highest rate of detections of PFAS are fish, shellfish, and organ meat (offal). In other categories of food,

PFAS are rarely detected. However, when PFAS are detected in other types of food, concentrations can

be quite high. The results of FDA and EFSA monitoring work are summarized in the following sections.

FDA monitoring – milk survey and Total Diet Study

The FDA is responsible for ensuring food safety from physical, chemical, and biological hazards. In 2012,

FDA analyzed 12 raw and 49 retail milk samples using a method developed specifically for PFAS analysis

in milk and found only one detection of PFOS (160 ng/L) which was later traced to a farm that amended

soils using contaminated biosolids. However, detection limits in this study were relatively high, at 130

ng/L. In 2019, FDA published a validated testing method for an expanded group of foods including

breads, cakes, fruits, dairy, vegetables, meats, poultry, fish, and bottled water. This method includes 16

PFAS analytes and has relatively high detection limits due to challenges associated with measuring PFAS

in a variety of foods with different chemical properties.

The FDA went on to use this method to analyze

samples that were collected in the FDA’s regular “Total Diet Study.”

Results from the initial testing of

PFAS in foods were used to determine how the FDA will monitor PFAS in foods going forward, including

whether steps should be taken to include PFAS in the Total Diet Study analytes, and if targeted sampling

for certain foods would be necessary. Results of preliminary Total Diet Study monitoring for PFAS found

that PFAS was only detected in two samples of fish (tilapia) and one sample of meat (ground turkey). All

other foods tested had PFAS concentrations below detection limits.

FDA has not announced intentions

to conduct any additional PFAS surveys in food.

European Food Safety Authority – exposure assessment for PFAS in food

The EFSA is the regulatory body in the European Union responsible for protecting the public, livestock,

and the environment against food-related risks. EFSA recently conducted an exposure assessment for

PFAS in food to serve as the basis of regulatory thresholds for PFAS in agriculture products.

This

exposure assessment included the review of 69,433 measurements of PFAS in food samples obtained

from 16 European countries. Overall, 92% of the data were below detection limits. Of the 26 PFAS with

data available, nine had no detections in food. The exposure assessment continued for the remaining 17

PFAS – PFBA, PFPeA, PFHxA, PFHpA, PFOA, PFNA, PFDA, PFUnDA, PFDoDA, PFTrDA, PFTeDA, PFBS,

PFHxS, PFHpS, PFOS, PFDS, and FOSA. The most data were available for PFOS, which had 8,498

measurements available in the database and PFOA, which had 8,197 measurements. There was also a

large amount of data available for PFNA, PFDA, PFHxA, and PFHxS, all of which had over 4,000

measurements available. In general, this assessment found that PFAS were found more frequently in fish

and other seafood and in meat and meat products (especially liver) than in other food groups. For PFOA,

PFOS and PFHxS, it appeared that prior agreements to phase out use of these substances resulted in a

EFSA. (2020). Outcome of a public consultation on the draft risk assessment of perfluoroalkyl substances in food. Retrieved

from: https://www.efsa.europa.eu/en/supporting/pub/en-1931

FDA. (2019). Determination of 16 Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) in Food using Liquid Chromatography-

Tandem Mass Spectrometry (LC-MS/MS). FDA Foods Program Compendium of Analytical Laboratory Methods: Chemical

Analytical manual (CAM). Retrieved from: https://www.fda.gov/media/131510/download

FDA. (n.d.). Total Diet Study. Retrieved from: https://www.fda.gov/food/science-research-food/total-diet-study

FDA (2019). FDA Makes Available Results from Second Round of Testing for PFAS in Foods from the General Food Supply.

Retrieved from: https://www.fda.gov/food/cfsan-constituent-updates/fda-makes-available-results-second-round-testing-pfas-

foods-general-food-supply

EFSA. (2020). Risk to human health related to the presence of perfluoroalkyl substances in food. Retrieved from:

https://www.efsa.europa.eu/en/efsajournal/pub/6223

Minnesota’s PFAS Blueprint • February 2021

decrease in concentration in food over time -- statistically significant decreasing trends were observed

for concentrations of PFOS and PFHxS in fish and eggs. Concentrations of PFOS in fish and eggs

decreased by a factor of 10 and 40, respectively. Overall, this report finds that most samples have no

PFAS or very low levels of PFAS that fall below the limit of detection. However, in locations where there

has been environmental contamination, it appears that PFAS can readily accumulate in fish, meat, eggs,

dairy products, fruits, and vegetables.

Regulation of contaminants in food

The FDA is the regulatory agency in the US responsible for measuring and regulating contaminants in

food. Tolerances are limits at or above which FDA will take legal action to remove products from the

market. When no established tolerance exists, FDA may take legal action against the product at the

minimal detectable level of the contaminant.

When it comes to PFAS, FDA has not set tolerances, as

they do for other environmental contaminants like PCBs and inorganic arsenic. FDA’s current policy is to

collaborate with states when they identify foods that are grown or produced in a specific geographic

area of PFAS contamination and provide technical assistance. This technical assistance can include

analyzing samples and assessing the likely safety of the levels of the contaminants found, if any. FDA

uses the EPA’s reference dose – the dose at which long-term exposure is unlikely to cause harm – as a

toxicity reference value for PFOA and PFOS when conducting a safety assessment at request of a state

agency. The PFOS and PFOA reference dose is of 0.02 μg of PFOS and PFOA ingested per kilogram of

bodyweight per day (2 x 10

-5

mg/kg-day). The FDA does not currently have toxicity reference values for

dietary exposure to any PFAS other than PFOA and PFOS.

The MDA also participates in ensuring food safety. Much of MDA’s regulatory work currently focuses on

foodborne pathogens like salmonella, listeria, and other biological contaminants. MDA responds to

contamination issues in food and adopts federal standards for contaminants in food like those for heavy

metals and dioxins, but does not actively survey food products for the presence of toxins. Because of the

variety of foods consumed and produced in Minnesota, creating an effective surveillance system would

be very difficult; even conducting monitoring of one food, such as milk, comes with many questions

about logistics, enforcement, and unintended consequences for the agricultural industry. A proactive

approach to managing PFAS, especially PFOS, is important to ensure that potential PFAS contamination

is halted upstream of the farm businesses. The burden of PFAS pollution should fall on sources of PFAS

(chemical production, industries with heavy PFAS use and emission) rather than the agricultural

community. MDA hopes to collaborate with farmers to identify upstream PFAS sources with the

potential to impact groundwater or feed and address this pollution at the industrial source before it

impacts livestock and crops.

Challenges to managing PFAS in food systems

There are many remaining challenges to effectively ensure that PFAS do not contaminate food sources

in Minnesota. Scientists are still studying several key subject areas including the relative contributions of

PFAS to plants and livestock from soil, water, and air, the variability in plant uptake based on plant

species and PFAS structure, PFAS transfer and accumulation from soil to feed to livestock, and spatial

variation in PFAS impacts. These topics are areas of interest and investigation at MPCA, MDA, and MDH.

Past and ongoing efforts

The following sections describe the efforts taken by MDH and MDA to investigate the potential for PFAS

exposure through food.

21 CFR 509. (2019). Unavoidable contaminants in animal food and food-packaging material. Retrieved from:

https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=509&showFR=1&subpartNode=21:6.0.1.1.5.1

Minnesota’s PFAS Blueprint • February 2021

Monitoring

Conducted study of PFAS in produce grown in East Metro home gardens

After PFAS contamination was discovered in the drinking water of several communities in the East

Metro Area, citizens raised concerns about the safety of consuming homegrown produce irrigated with

PFAS-contaminated water. MPCA partnered with MDH to conduct a study using funding from the 3M

settlement to investigate this question. The study was conducted at homes in Lake Elmo, Oakdale, and

Cottage Grove during the 2010 growing season to assess levels of PFAS in exterior tap water, garden soil,

and garden produce. The objective of the study was to determine the extent to which current or past

use of contaminated water for irrigation influenced levels of PFAS in garden soil and homegrown

produce. A secondary objective was to build the capacity of the MDH public health lab to conduct multi-

media analysis of PFAS.

Homes were eligible to be included in the study if they were served by the Oakdale public water system

or private wells known to have detectible levels of PFOA or PFOS. Drinking water mitigation measures

were already in place at these homes, but exterior taps were not treated. Produce gardens had to be at

least 50 square feet and in use continuously for the last five years in the same location. The first 20

households that responded to MDH’s invitation letter and met eligibility requirements were enrolled.

MDH also enrolled three households outside the groundwater contamination area with large home

produce gardens as a comparison group. Pre- and post-gardening surveys were administered to

homeowners to assess gardening practices. The MDH Public Health Lab (PHL) analyzed exterior tap

water, soil, and the mature, edible portions of plants for PFBA, PFPeA, PFHxA, PFOA, PFBS, PFHxS, and

PFOS. Laboratory methods were published in a peer-reviewed journal.

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A total of 343 water, soil, and produce samples were analyzed in this study. In outside tap water, PFBA

was found most often (85%) and at the highest concentrations (median=0.98 μg/L); followed by PFPeA

(40%) and PFOA (25%). In garden soil, PFBA, PFOA and PFOS were found in 100% of samples; median

concentrations in soils in the groundwater contaminated area were 2-3 times higher compared to

garden soil at homes outside the groundwater contaminated area. In produce, PFBA was detected most

often (98%) and at the highest concentrations, followed by PFPeA (38%). The median PFBA produce

concentration (0.68 μg/kg) was 10 times higher inside versus outside the groundwater contaminated

area. The level of PFBA in produce depended on which produce type was analyzed, the part of the

produce measured (i.e., floret, stem, root), and the amount of garden watering reported in the

gardening survey. Detailed results were published in a peer-reviewed journal.

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MDH conducted a risk

assessment based on the results. No health risks of concern were found for those living in East Metro

communities when considering combined risk from multiple exposure pathways.

Work status: completed

Leaders: MDH Environmental Surveillance and Assessment. Partners: MDH Public Health Lab and

MPCA Remediation.

Benefits: This study highlighted the high leaching potential and high plant uptake rate of shorter-

chain PFAS. This study found that when longer-chain PFAS like PFOS and PFOA were present in soil,

they were not as readily translocated through plants as short chain PFAS like PFBA. This study was

able to address concerns expressed by East Metro community members about eating fruits and

vegetables that have been grown in soil or irrigated with water that contains PFAS. Additionally,

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Huset C.A. & Barry K. (2018). Quantitative determination of perfluoroalkyl substances (PFAS) in soil, water, and home garden

produce. Methods, 28; (5), 697-704. doi: 10.1016/j.mex.2018.06.017.

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Scher D.P., Kelly J.E., Huset C.A., Barry K.M., Hoffbeck R.W., Yingling V.L., & Messing R.B. (2018). Occurrence of perfluoroalkyl

substances (PFAS) in garden produce at homes with a history of PFAS-contaminated drinking water. Chemosphere, 196, 548-

555. doi: 10.1016/j.chemosphere.2017.12.179.

Minnesota’s PFAS Blueprint • February 2021

samples of dust and soil conducted during this investigation allowed MDH to draw conclusions

about relative risks of children’s exposure to PFAS through dust or incidental soil ingestion in the

groundwater contaminated area. This study also contributed to the availability of analytical methods

for PFAS. Before MPCA conducted this study, there were no published methods for measuring PFAS

in produce and limited study of PFAS exposure from garden produce.

Challenges: Developing analytical methods to quantify PFAS concentrations in various types of

produce was challenging. Because the produce tested in this study had different characteristics –

such as high acidity, or high moisture – methods needed to be tailored to groups of produce with

similar chemical characteristics (see the Measuring PFAS Effectively and Consistently Issue Paper for

more information).

Resources: The initial 2010-2011 budget in the MDH-MPCA interagency contract was $468,512. This

budget also included costs related to collection and analysis of house dust samples at each home.

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Staff resource needs were high, as study staff had to visit homes several times over the growing

season to collect samples and administer surveys. This was helped by the proximity of the study

area to the MDH offices and laboratory.

Source reduction

Investigated presence of PFAS additives to pesticides registered for use in Minnesota

In 2007, the MDA examined pesticide active and inert ingredients as a potential source of PFAS. Based

on the information received from the EPA and the Minnesota pesticide registration database, MDA

concluded that pesticides are not a significant source of PFAS. The MDA was not aware of and did not

consider any potential contribution from PFAS in pesticide containers. The MDA’s review found that

Sulfluramid (a pesticide with an active ingredient that rapidly degrades to PFOS) was registered in

Minnesota from 2006 to 2012. Sulfluramid-based products were sold as prefilled bait stations for control

of ants, cockroaches, and termites in buildings, or bait stations for termite control around foundations,

but had limited use in Minnesota. Sales of Sulfluramid in Minnesota remained near zero (0.01 to 0.21

lbs. per year) from 2006 to 2012 because of the limited need for termite control in Minnesota.

The review additionally found that PFAS were components of only one pesticide inert ingredient

(Fluowet PL-80). Federally registered pesticide products containing this inert ingredient were registered

for use from 2001 to 2008. The EPA cancelled all uses for this inert ingredient by February 2008.

Products that contained this inert ingredient were registered in Minnesota from 2001-2006. The

registered pesticide products carried low concentrations (≤ 0.5%) of PFAS in the final product

formulation, suggesting very low rates of PFAS application through pesticides containing this inert

ingredient. Additionally, recent testing of a pesticide used for mosquito control (Anvil 10-10) found PFAS

that were introduced through packaging.

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MDA has investigated potential PFAS releases from use of

Anvil 10-10: the active ingredient in this product is phenothrin. There are several products registered in

Minnesota which have phenothrin as an active ingredient. Phenothrin sales from all field applied

products in Minnesota were on average about 1,000 lbs/year. MDA has concluded that Anvil 10-10 use

is not a significant source of PFAS in the state.

Work status: completed

Leader: MDA Pesticide and Fertilizer Management Division.

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Scher D.P., Kelly J.E., Huset C.A., Barry K.M., & Yingling V.L. (2019). Does soil track-in contribute to house dust concentrations

of perfluoroalkyl acids (PFAAs) in areas affected by soil or water contamination? Journal of Exposure Science Environ

Epidemiology, 29, (2), 218-226. doi: 10.1038/s41370-018-0101-6.

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Abel, D. (2020, Dec 1). Toxic ‘forever chemicals’ found in pesticide used on millions of Mass. Acres when spraying for

mosquitoes. Boston Globe. Retrieved from: https://www.bostonglobe.com/2020/12/01/metro/toxic-forever-chemicals-found-

pesticide-used-millions-mass-acres-when-spraying-mosquitos/

Minnesota’s PFAS Blueprint • February 2021

Benefits: Inclusion of PFAS in pesticides could be damaging for several reasons. Spraying of PFAS-

containing pesticides could cause widespread PFAS contamination of soil, surface water, and

groundwater. Additionally, any use of PFAS in pesticides on plants grown for human consumption

could result in increased exposure to consumers. Even use of PFAS-containing pesticides on plants

grown for feed could result in human exposure through bioaccumulation from the plants into

livestock. Ensuring that no PFAS containing pesticides were currently registered for use in Minnesota

and that historic applications of PFAS containing pesticides likely resulted in minimal amounts of

environmental release helped focus attention to other opportunities for PFAS source reduction to

agriculture.

Challenges: All inert ingredients in pesticide products, including those in inert mixtures, must be

approved by the EPA. However, not all inert ingredients are required to be disclosed on the product

label. Ensuring that PFAS were not included as inert ingredients required contacting pesticide

manufacturers and federal regulators. Only PFOS and PFOA are restricted for use in pesticide

products – so there could be new pesticides incorporating PFAS as inert ingredients. Although it is

unlikely that EPA would approve PFAS as active ingredient or as an inert ingredient in new pesticide

formulations, PFAS are not disallowed for use in these products.

Resources: This effort required time of MDA staff to investigate potential undisclosed PFAS

additions to pesticides registered in Minnesota, but it did not require any supplemental funding.

Repeating this investigation would be needed to determine if new PFAS inert ingredients were used

in Minnesota after this investigation took place in 2008.

Gaps and opportunities

There are many remaining gaps in information and action around PFAS and Minnesota’s food systems.

Many farmers in Minnesota are likely unaware of the potential risks that environmental PFAS

contamination can pose to their products. Farmers generally do not use PFAS themselves, and may not

be aware of the PFAS emissions by other entities that may have pathways to reach their property. MPCA

is taking many actions to reduce the overall release of PFAS into the environment (see the Preventing

PFAS Pollution Issue Paper), but additional interventions may be needed to address past and ongoing

sources of PFAS that may reach farms. MDA and MPCA could help farmers identify upstream sources of

PFAS and collaborate with farmers prevent those sources from causing PFAS loading in their farms.

These agencies could provide grants to aid in this upstream source identification process.

Additionally, there are significant gaps in understanding of how contaminated biosolids may be

impacting PFAS levels in food. Due to the many beneficial outcomes of land-applying biosolids, there is a

desire to develop screening levels and tools to determine in what contexts land-applying biosolids is a

safe and responsible practice. Additional research on the fate of PFAS in land-applied biosolids is needed

to develop these tools and continue reaping the positive effects of biosolids application.

Education

Inform and engage with farmers about potential upstream sources of PFAS

Recent research shows that high levels of PFOS in milk may be possible if avenues of exposure to PFOS

for dairy farms, and the animals on those farms, are not controlled. Because this is a relatively new

discovery, livestock producers and associated industry stakeholders are not always knowledgeable

about PFAS, including PFOS, and what the potential paths of exposure for farms might be. This project

would be designed to educate farmers on PFOS contamination as a public health problem, and the

possible pathways for PFOS exposure to dairy farms. With a baseline understanding of this issue, dairy

farmers can make decisions to ensure that they are limiting, to the extent possible, exposure and are

preventing contamination of milk before it occurs.

Minnesota’s PFAS Blueprint • February 2021

The MDA could work with MPCA to identify and limit PFOS pollution from point sources in agricultural

areas so that the impacts to dairy farms are limited. Voluntary and free testing of feed, biosolids, or

other potential upstream PFAS sources would help proactively identify potential routes for PFAS to

enter farmland and to provide information that could be used to stop pathways for PFAS contamination

before they reach the farm. The goals of this work are not regulatory in nature, but rather to expand the

knowledge base and identify areas for any needed upstream intervention that would protect farmers

from PFAS pollution caused by other industries.

Work status: under consideration

Leader: MDA Dairy and Meat Inspection Division, Dairy Inspection Program. Partners: MPCA

Remediation, dairy cooperatives, livestock producers.

Benefits: Educational programs equip farmers with the knowledge and, in some cases, the means to

address issues proactively. This program will encourage action, but not penalize the dairy producer

for things that are largely unknown or out of their control. It would also provide a means to collect

information that may further our understanding of these issues with respect to animal agriculture

and our food supply.

Challenges: Effective outreach depends upon adequate knowledge and planning, good strategies for

working cooperatively with farmers, and trusted relationships between agency staff and farmers.

MDA and MPCA both have regulatory and outreach functions -- it is important to separate outreach

from regulation in this project. Any negative implications to a farmer’s ability to market their

products would significantly impact the success of the project, especially during times when the

dairy and other agricultural industries are challenged. Agricultural industries are not expected to

have funds to support such work, even on an informal basis.

Resources: This effort would involve multiple staff from MDA and MPCA to oversee these efforts

and conduct outreach activities. Staff would be needed to develop communication and education

materials and deliver training, both on a one-on-one basis, and with group outreach efforts.

Additionally, if sampling of potential upstream sources or surveys were included, funding would be

needed to pay for sampling and for staff to coordinate sampling and collection of survey information

in conjunction with sampling projects undertaken.

Research

Conduct a study of biosolids and feed crop uptake

While land application of biosolids has benefits for farming, land application has been a source of PFAS

to groundwater, soil, surface water, crops, and, in some cases, livestock. There are many unknowns

regarding how PFAS moves out of biosolids and into the environment and food supplies. These gaps in

knowledge about PFAS fate and transport in biosolids make it difficult to proactively manage biosolids in

a way that prevents contamination of food systems and protects farmers against the financial burdens

associated with PFAS contamination. The goal of this study is to collect data that would inform tools

used to evaluate PFAS risks in land-applied biosolids and manage biosolids appropriately. Specifically,

this project proposes 1) to evaluate and characterize PFAS concentrations in land‐applied biosolids;

leaching from those wastes; and subsequent movement of PFAS into water and food and 2) to analyze

alternative disposal and treatment options and develop tools for managing PFAS‐contaminated waste

streams. This project was recommended for funding under the Legislative-Citizen Commission on

Minnesota Resources (LCCMR) process, but funding for all LCCMR projects was not secured for the

entire 2020 set of proposals. Nevertheless, a full description of the project, as proposed to LCCMR, is

available online.

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This project is also discussed in the Managing PFAS in Waste Issue Paper.

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LCCMR (2020), Environment and Natural Resources Trust Fund, 2020 Request for Proposals (RFP). Retrieved from:

https://www.lccmr.leg.mn/proposals/2020/originals/098-b.pdf

Minnesota’s PFAS Blueprint • February 2021

Work status: proposed

Leader: MPCA Environmental Analysis and Outcomes Division. Partners: Participating wastewater

treatment plants and academic partners at University of Minnesota and Texas Tech University.

Benefits: This project will develop pollution prevention, treatment, and disposal options that can be

applied statewide. Long‐term implementation of these strategies will safeguard drinking water and

food supplies for current and future needs. Additionally, proactive biosolid management strategies

with regard to PFAS will prevent financial hardship to farmers who would otherwise be challenged

to sell PFAS-contaminated products.

Challenges: There will likely be challenges that would need to be overcome to complete this (or a

similar) project. Analytical costs for conducting sampling are high (most PFAS samples cost between

$300-400 for each sample to be analyzed). Understanding the fate of PFAS after land-application

requires sampling in multiple media, including surrounding surface water, pore water in soils, down-

gradient groundwater, crops planted on the biosolids amended field, and the soil itself. Finding

fields for biosolid amendment that do not already have PFAS present would be a challenge. Using

the results of the Minnesota study (and similar studies currently being undertaken by Wisconsin,

Michigan, and New Hampshire) to develop a tool to determine risk levels and application strategies

for biosolids would require significant time and effort.

Resources: This project proposal is complex, and would likely require about $1.4 million to complete

in full. However, some aspects of the project proposal could be completed as standalone projects

that require less funding.

Regulation

Limit or ban PFAS in food packaging materials

Many studies have indicated that food packing is a potential source of PFAS exposure through food,

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and that disposal of food packaging materials containing PFAS results is a significant loading of PFAS to

landfill leachate.

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As noted previously, food contact substances – such as those in food packaging – are

regulated by the FDA: “Food packaging manufacturers must prove to the US FDA that all materials

coming in contact with food are safe before they are permitted for use in such a manner.”

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The FDA

has taken some actions to remove authorization for the use of long-chain PFAS in food-contact uses,

primarily with voluntary participation by manufacturers. The FDA’s website states:

“The FDA had authorized the use of long-chain PFCs for specific food-contact uses such as coatings

on fast-food wrappers, to-go boxes, and pizza boxes before new scientific information brought

safety concerns to light. In 2010, the FDA identified safety concerns through a comprehensive

review of the available literature. These safety concerns included systemic and developmental

toxicity in combination with biopersistence. The FDA then worked with industry to stop distribution

of the long-chain PFCs most commonly used in food packaging at that time, which are authorized

under food contact notifications. By October 1, 2011 these manufacturers had assured the FDA that

they had voluntarily stopped distributing these long-chain PFCs.”

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105

Susmann, H., Schaider, L., Rodgers, K., & Rudel, R. (2019). Dietary habits related to food packaging and population exposure

to PFAS. Environmental Health Perspectives. 127, 10. https://doi.org/10.1289/EHP4092

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PFAS waste source testing report, New England Waste Services of Vermont. (2019).

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FDA. (2010). Overview of Food Ingredients, Additives & Color. Retrieved from: https://www.fda.gov/food/food-ingredients-

packaging/overview-food-ingredients-additives-colors

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FDA. (2016). FDA Removes Approval for the Use of PFCs in Food Packaging Based on the Abandonment. Retrieved from:

https://www.fda.gov/food/cfsan-constituent-updates/fda-removes-approval-use-pfcs-food-packaging-based-abandonment

Minnesota’s PFAS Blueprint • February 2021

Subsequently, in 2016, 3M informed the FDA that they were no longer making two additional long-chain

PFAS, and so those were also proposed to be removed from the list of authorized substances.

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In early

2020, additional concerns arose at FDA over short-chain PFAS. FDA “published findings from a post-

market scientific review and analysis of data…on 6:2 fluorotelomer alcohol (6:2 FTOH).The data raise

questions about the potential human health risks from dietary exposure resulting from these authorized

uses of short-chain PFAS that contain 6:2 FTOH. Four manufacturers hold 15 food contact notifications

for 11 compounds that may contain 6:2 FTOH.”

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This concern over exposure to 6:2 FTOH in food

packaging led to the voluntary phase-out of its use (by 2024) by manufacturers.

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The voluntary nature of FDA action to date has led to Congressional proposals to ban PFAS in food

containers and cookware, such as the Keep Food Containers Safe from PFAS Act, HR 2827, introduced in

May 2019 by Rep. Dingell (D-MI)

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and the Prevent Future American Sickness Act of 2020, S.3227,

introduced in January 2020 by Sen. Sanders (I-VT).

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Some regulatory action has been taken – the 2020

National Defense Authorization Act (P.L. 116-92), “prohibits the use of PFAS in food packaging for

military meals ready-to-eat after October 1, 2021.”

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Without bans at the federal level, some states are taking action. California, Washington, New York, and

Maine have taken actions to phase-out all intentionally added PFAS to food packaging

materials.

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116

117

118

The Toxics in Packaging Clearing House, a non-profit that promotes consistent

packaging regulation across states and supports companies seeking information on food packaging

requirements, recently developed model legislation for a state-level PFAS in food packaging ban.

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Legislative action of some kind would be needed to ban PFAS in food packaging at either the state or

federal level. Minnesota could consider legislative action to ban the addition of PFAS to packaging,

leveraging the policy research already completed by the Toxics in Packaging Clearing House. This

proposal could be part of a larger proposal to review PFAS uses in consumer projects or could be a

standalone proposal to ban PFAS in food packaging. The state could also be more active in pushing for

action on PFAS in food contact materials at the federal level.

Work status: under consideration, would require legislative action

Leader: MPCA. Partners: Other state agencies.

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FDA. (2016). FDA Removes Approval for the Use of PFCs in Food Packaging Based on the Abandonment. Retrieved from:

https://www.fda.gov/food/cfsan-constituent-updates/fda-removes-approval-use-pfcs-food-packaging-based-abandonment

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FDA. (n.d.). Authorized Uses of PFAS in Food Contact Applications. https://www.fda.gov/food/chemicals/authorized-uses-

pfas-food-contact-applications

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FDA. (2020). FDA Announces the Voluntary Phase-Out by Industry of Certain PFAS Used in Food Packaging.

https://www.fda.gov/food/cfsan-constituent-updates/fda-announces-voluntary-phase-out-industry-certain-pfas-used-food-

packaging

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Keep Food Containers Safe from PFAS Act of 2019. (2019). H.R. 2827. 116 Cong. (2019-2020).

https://www.congress.gov/bill/116th-congress/house-bill/2827/text/ih

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Prevent Future American Sickness Act of 2020. (2020). S. 3227. 116

Cong. (2019-2020).

https://www.congress.gov/bill/116th-congress/senate-bill/3227

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The National Review. (2020, March 23). Attack on PFASs Extends to Food Packaging. Retrieved from:

https://www.natlawreview.com/article/attack-PFAS-extends-to-food-packaging

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Attack on PFASs Extends to Food Packaging. (2020). National Law Review. https://dtsc.ca.gov/scp/food-packaging-

containing-pfass/

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An Act To Protect the Environment and Public Health by Further Reducing Toxic Chemicals in Packaging. Retrieved from:

http://www.mainelegislature.org/legis/bills/display_ps.asp?ld=1433&PID=1456&snum=129

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WA Toxics in Packaging Law - Chapter 70.95G RCW; 2018 revisions in Engrossed Substitute House Bill 2658, Chapter 138,

Laws of 2018

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An Act to amend the environmental conservation law, in relation to the use of perfluoroalkyl and polyfluoroalkyl substances

in food packaging. Retrieved from: https://www.nysenate.gov/legislation/bills/2019/s8817

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Toxics in Packaging Clearinghouse. https://toxicsinpackaging.org/

Minnesota’s PFAS Blueprint • February 2021

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Benefits: Humans have been shown to be exposed to PFAS through eating food that has been in

contact with PFAS-containing food packaging materials. Phasing-out the sales of PFAS-containing

food packaging will have the direct benefit of reducing dietary exposure to PFAS. Additionally, PFAS

have been shown to accumulate in landfill leachate, compost contact water and biosolids from

wastewater treatment plants; a study of sources of PFAS to a landfill in Vermont indicated that the

most “leachable” PFAS sources to the landfill were PFAS in food packaging materials. Reducing the

loading of PFAS to landfills, composting facilities, and wastewater treatment plants will reduce the

PFAS leaving those facilities and entering into the environment (including farmlands).

Challenges: Some food packaging materials have small amounts of PFAS due to use of recycled

paper and incidental inclusion of PFAS from other sources (like PFAS in the trees used to make the

paper). Regulations of PFAS in food packaging would likely need to set thresholds above which it is

assumed that PFAS has been intentionally added, and therefore the product is not allowed to be

sold. Enforcement of PFAS bans would likely require equipment, such as a Particle-Induced Gamma

Ray Emission (PIGE) spectrometer, which can be used to rapidly determine if PFAS has been added

to a material.

Resources: Though developing a legislative proposal to phase-out PFAS uses in food packaging

materials in Minnesota would not require significant additional resources, enacting a Minnesota

specific phase-out (should it be passed into law) would likely require significant funding for testing

and enforcement. A federal ban would not have resource implications for Minnesota agencies

because it would be developed and enforced at the federal level.

Overview of intersectional issues

 Pollution prevention: Reducing PFAS pollution at the source places the burden with the 

polluters rather than farmers and the public. The breadth of PFAS in use in products and industry

and ongoing registration of new PFAS means that environmental monitoring, risk assessment and

management strategies cannot keep up. See the Preventing PFAS Pollution Issue Paper for

actions related to reducing the overall production and emission of PFAS products. 

 Reducing PFAS exposure from consuming local fish and game: Though action is needed to

better understand potential PFAS exposure from agriculture products like produce, dairy, and

meat, hunters and fishers consuming animals caught in PFAS-contaminated areas are known to

have potentially high levels of PFAS exposure. Minnesotans who eat organs from game, like

animal liver or heart muscle, are especially vulnerable. Understanding total dietary exposure to

PFAS will require consideration of exposure from contaminated game and fish along with any

potential dietary exposure from other food sources.

 Quantifying PFAS toxicity: Having an understanding of the potential health impacts of PFAS

exposure is key in ensuring exposure stays below “safe” thresholds and communicating with the

public. Health-based guidance values, however, require data on toxicity and exposure that are

not available for the vast majority of all the PFAS found in the environment. See the Quantifying

PFAS Risks to Human Health Issue Paper for more information on challenges stemming from

PFAS toxicity data limitations.  

 Developing and expanding access to analytical methods:  Analytical methods for PFAS are

expensive and time-intensive to run, and include only a subset of all PFAS that may be occurring

in food. Increased access to non-targeted analysis and cheaper screening-level PFAS

methods would be beneficial for protecting consumers of food – see the Measuring PFAS

Effectively and Consistently Issue Paper for more information on the costs and challenges

associated with measuring PFAS in biological matrixes.  

Minnesota’s PFAS Blueprint • February 2021

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Understanding risks from PFAS air emissi ons

Background

 Clean air is essential for maintaining health of our communities, thriving ecosystems, and a sustainable

economy.

 PFAS can exist in the air in multiple forms: PFAS can be a gas or attached to particulate material

suspended in the air. Particulate and gaseous PFAS can transport long distances.

 PFAS emissions to air result in concerns over toxicity to humans from inhaling PFAS and transfer of

PFAS from air to other environmental media like soil, surface water, and fish.

 There is currently limited information about toxicity of PFAS from air exposure, and there are no

PFAS screening values available from MDH or EPA.

 There are multiple examples from Minnesota and other states of facilities emitting PFAS to the air

that goes on to contaminate soil, surface water, and other media. For example, a recent study of

PFAS emissions indicates that a single facility in New Jersey resulted in PFAS soil contamination as

far away as New Hampshire.

 New site-specific criteria for PFOS developed under the CWA indicate that very low levels of PFOS

in surface water can result in PFOS accumulating in fish to concentrations exceeding health-based

values – this generates concern that air emissions of PFOS could cause or contribute to water

quality impairments for PFOS.

 The ability of a single facility to pollute a widespread region with highly persistent and toxic

compounds makes controlling PFAS emissions to the atmosphere an important element of the

PFAS management strategy.

 The Clean Air Act (CAA) is the foundational law for protecting air quality in the US Under the CAA, EPA

regulates emissions of 187 air toxics (called Hazardous Air Pollutants or HAPs).

 PFAS are not included as HAPs under the CAA.

 Though there are currently no regulations on PFAS emissions to the air in Minnesota, there are

mechanisms in the state and federal government to either voluntarily request or mandate reporting

on some PFAS emissions from facilities that use or produce PFAS products.

 The federal Toxics Release Inventory (TRI) requires some facilities to report releases of listed

contaminants. PFAS were added to the TRI list for reporting year 2020, but exemptions will result in

continued unreported PFAS releases.

 Emissions reporting is not required for PFAS considered “confidential business information,” and

therefore the TRI only includes 172 PFAS.

 Reporting is not required if the facility releases less than 100 pounds (~45,000 g) per year of PFAS-

containing materials. (For comparison, it is estimated that 0.4 - 1 g/year of PFOS released from a

metal plating site resulted in exceedances of a site-specific surface water criteria and a “do not

eat” fish consumption advisory in a nearby lake).

 Reporting is not required if the material released contains less than 1% PFAS or 0.1% PFOA.

 Facilities employing fewer than 10 full-time staff are not required to participate in TRI reporting.

 MPCA requests that facilities voluntarily provide emissions data every three years on air toxics; MPCA

uses this information to prepare the statewide air toxics inventory submittal to EPA’s National

Emissions Inventory. This is separate from the federal TRI program.

Understanding risks from PFAS air emissions

Summary

Minnesota’s PFAS Blueprint • February 2021

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What is Minnesota doing now?

 For reporting year 2020, MPCA requested voluntary reporting of PFOS, PFOA, PFBS, PFHxS, and

PFBA to the Air Emissions Inventory as part of a larger request that facilities report on several

contaminants not designated as HAPs under the CAA.

 Not all facilities will participate in this voluntary reporting request for various reasons, which may

include the costs associated with estimating emissions and preparing the report.

 MPCA is conducting a year-long PFAS monitoring project, which includes the collection of ambient air,

wet deposition, and dry deposition samples at four sites across Minnesota.

 One “background” air monitoring site is located in Grand Portage, and three urban sites

(St. Louis Park, Eagan, and Duluth) are located near potential emission sources. These locations

were chosen to increase our understanding of PFAS sources and atmospheric transport.

What are remaining gaps and opportunities for action?

 Gap: Despite recent progress in requiring mandatory reporting of PFAS releases to the EPA through the

TRI, exemptions in this federal program will result in gaps in the PFAS release data.

 Opportunity: MPCA could consider making air toxics (including PFAS) emission reporting

mandatory.

 Opportunity: MPCA could require permitted facilities to conduct performance tests for PFAS and

report results.

 Gap: There is currently a lack of modeling capability to understand how PFAS emissions to the air

influence surface water, soils, sediment, and fish in the surrounding region.

 Opportunity: Developing a model that includes cross-media considerations of exposure for persistent

and bioaccumulative compounds, starting with PFOS, could be used to assess cross-media risks and fill

gaps associated with unknown degrees of environmental loading from air.

How does this work benefit human health and the environment?

 Efforts to understand which facilities are releasing PFAS will help MPCA and MDH prioritize

investigations into drinking water, surface water, fish, and soil.

 Having the tools to demonstrate how air emissions may cause exposures to humans through

multiple routes may help MPCA develop future strategies to reduce emissions and health impacts.

How does this work benefit Minnesota’s economy?

 Reducing PFAS pollution by controlling PFAS releases from industrial sources places the financial

burden of PFAS controls with polluters. This reduces the costs borne by waste and drinking water

facilities -- many of which are publicly funded – who otherwise may need to manage and treat PFAS.

 Reducing PFAS pollution also prevents costs to consumers associated with decreased opportunities to

harvest local fish and game that may be contaminated due to air emissions.

 Preventing adverse physical health outcomes associated with PFAS exposure and preventing negative

mental health outcomes associated with concern over exposure to these compounds is financially

beneficial for families and individuals.

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Background

Clean air is essential for maintaining the health of our communities, thriving ecosystems, and a

sustainable economy. In the context of environmental management of PFAS, air is a critical topic for two

reasons. First, there is limited information about human exposure to PFAS in the air, especially in

communities surrounding facilities that are likely releasing PFAS to the atmosphere through their

production of PFAS, use of PFAS products, or burning of PFAS-containing waste. These concerns about

the potential for direct toxicity to humans from inhalation of PFAS is motivating ongoing research.

Secondly, air is a critical topic in PFAS management because there have been many documented cases

of PFAS emissions to air resulting in significant impacts in other environmental media like surface water,

soil, and biota.

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PFAS may transform to other PFAS, but the carbon-fluorine bonds characteristic of PFAS do not break

down in the environment. When PFAS are released to the air, they can sometimes travel long distances

in the atmosphere before they are deposited to the surface in rain or through dry settling processes. For

example, a recent study of PFAS emissions indicates that a single PFAS facility in New Jersey potentially

resulted in PFAS soil contamination as far away as New Hampshire.

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PFAS have been found to

accumulate in high concentrations in snow and biota in the Arctic due to patterns of long-range

atmospheric transport.

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PFAS can exist in the gas phase or can sorb to particulate material suspended

in the air – both particulate and gaseous PFAS can be transported long distances. This high potential for

PFAS to move through the atmosphere and contaminate other environmental media is the second

reason why there is continued focus and concern regarding PFAS emissions to the air.

Regulatory structure controlling air emissions

The CAA is the foundational law for protecting air quality in the US Under the CAA, EPA sets National

Ambient Air Quality Standards for six important air pollutants called Criteria Air Pollutants (CAPs), which

include particulate matter in two size fractions, sulfur dioxide, nitrogen oxide, ozone, and carbon

monoxide. The CAA additionally requires the EPA to regulate the emissions of 187 specific air toxics,

referred to as Hazardous Air Pollutants (HAPs). The EPA regulates HAPs through National Emission

Standards for Hazardous Air Pollutants (NESHAPs), which require the maximum degree of reduction

achievable with modern pollution control technologies (known as maximum achievable control

technology, or MACT). In Minnesota, potential health effects from air This process involves using risk

screening tools to assess the potential for adverse health impacts from those air toxics, and potentially

conducting more detailed risk assessments, as needed. PFAS are not included as CAPs or HAPs under the

CAA, and are therefore largely unregulated in air. However, if a facility is shown to be causing or

contributing to a water quality impairment, meaning that releases of the pollutant to any media are

causing a surface water to not meet its “beneficial uses” under the CWA, then an enforcement action

such as instituting a schedule of compliance (which could include requirements to reduce all PFAS

emissions) might be an option to reduce air emissions.

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Ahrens. L., & Bundschuh, M. (2014). Fate and effects of poly- and perfluoroalkyl substances in the aquatic environment: A

review. Environmental Toxicology and Chemistry, 33 (9):1921-1929. DOI: 10.1002/etc.2663

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Washington, J., Rosal, C.G., McCord, J.P., Strynar, M.J., Lindstrom, A.B., Bergman, E.L., Goodrow, S.M., Tadesse, H.K., Pilant,

A.N., Washington, B.J., David, M.J., Stuart, B.G., & Jenkins, T.M. (2020). Non-targeted mass-spectral detection of

chloroperfluoropolyether carboxylates in New Jersey soils. Science, 368, (6495), 1103-1107. Doi: 10.1126/science.aba7127

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Joerss, H., Xie, Z. Wagner, C.C., von Appen, W., Sunderland, E.M., & Ebinghaus, R. (2020). Transport of legacy perfluoroalkyl

substances and the replacement compound HFPO-DA through the Atlantic Gateway to the Arctic Ocean – is the Arctic a sink or

source? Environmental Science and Technology, 54, (16), 9958-9967. https://doi.org/10.1021/acs.est.0c00228

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Risks associated with PFAS air emissions

There are two types of risk associated with PFAS in the air: risks from direct inhalation exposure to PFAS

in air and risks from exposure to PFAS from drinking water, food, dust, or other media that was

contaminated via the atmospheric deposition of PFAS from air. Comparing pollution levels to “health

benchmarks” is one way to estimate risk. A health benchmark is a level below which a pollutant is

unlikely to cause adverse health effects in sensitive populations. Benchmarks are calculated for each

type of media. PFAS benchmarks have been derived by MDH and MPCA for media such as drinking water

and soil, but no MPCA-specific PFAS benchmarks have been derived for air due to a lack of relevant

toxicological and occurrence data. Although PFAS are not designated HAPs under the CAA, there is

interest in developing more tools – like health benchmarks – that recognize the potential for PFAS

inhalation toxicity.

Based on the limited data available, PFAS exposure from drinking water, food, and dust is a larger source

than exposure directly from air inhalation in most residential settings. Proximity to an air emission

source for PFAS, like a PFAS remediation site or an industrial facility using PFAS, may result in different

exposure patterns. Though Minnesota does not currently have inhalation health-based screening levels

available for PFAS, Michigan has derived inhalation health-based screening levels for PFOA and PFOS.

Michigan found that most PFOA and PFOS levels reported in outdoor air in the published literature were

below the inhalation health-based screening levels. The only areas with PFAS concentrations that

exceeded the health-based standards were found around a large PFAS manufacturing facility in West

Virginia.

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While these are encouraging preliminary findings about risks from direct exposure to PFAS in

the air for the general public, those living near PFAS producing facilities and PFAS remediation sites may

have higher exposure to PFAS via air. As more is learned about the health impacts from inhalation and

about levels of PFAS in the air over time, inhalation health-based screening levels may be developed and

refined. Currently, it is known that managing PFAS in air is a way to prevent PFAS contamination of soil,

water, and food like fish, game, and produce. New studies of PFAS and plants indicate that PFAS in air is

contributing to uptake or sorption to plant leaves (see Limiting PFAS Exposure from Food Issue Paper),

which can contribute to contamination of livestock or exposure directly to humans. Additionally, dry and

wet deposition of PFOS or PFOS-precursors from air emission sources could be significant enough to

cause an exceedance of MPCA’s site-specific water quality criteria for PFOS in fish tissue and water.

More research is needed into what levels of PFOS and PFOS-precursor air emissions cause sufficient

loading of PFOS in surface waters to result in water impairments under the CWA.

PFAS emissions and monitoring data

Although there are currently no state or federal regulations limiting PFAS emissions to the air, there are

mechanisms in the state and federal government to either voluntarily request or mandate reporting on

some PFAS emissions from facilities that use or produce PFAS products. At the federal level,

amendments to the 2020 National Defense Authorization Act required that EPA, using the TRI, mandate

reporting on emissions of PFAS that have a structural identity determined not to be “confidential

business information.” Despite the new reporting requirements under TRI, there are several exemptions

that result in situations where PFAS will not need to be reported. TRI requirements only apply to

facilities that employ more than 10 staff. If the PFAS emissions are less than 100 pounds per year, the

facility does not need to report any release data. Additionally, if the PFAS-containing product emitted

contains less than 1% PFAS or 0.1% PFOA, these emissions do not need to be reported, regardless of the

quantity of product released. Finally, the facilities will only need to report PFAS emissions for the listed

PFAS (172 are listed), not all PFAS (of which there are over 5,000). This reporting data will be available

for the first time in the summer of 2021. In a comment letter to EPA on the additions of PFAS to the TRI,

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Michigan PFAS Action Response Team (MPART). (n.d.). Air quality related issues. Retrieved from:

https://www.michigan.gov/pfasresponse/0,9038,7-365-86704_94366---,00.html

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MPCA argued that a reporting threshold of 0.1 g/year, as is in effect for dioxins, is the appropriate

reporting threshold for mandatory PFAS emissions reporting. This conclusion was reached by calculating

that 0.4 - 1 g/year of PFOS emissions associated with a metal plating facility in Minnesota caused

exceedances of site-specific surface water criteria for PFOS and resulted in a “do not eat” fish advisory in

a nearby lake.

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The existing reporting thresholds of 100 pounds/year for PFAS would not capture

smaller PFAS releases that are still significant.

At the state level, MPCA does not have mandatory reporting requirements for emissions data of

contaminants that are not HAPs. However, MPCA requests that facilities voluntarily provide air toxics

emissions data every three years; MPCA uses this information to prepare the statewide air toxics

inventory submittal to EPA’s National Emissions Inventory. If a facility does not respond to the voluntary

request to report air toxics, the MPCA may estimate toxics emissions by using information from permits

and the mandatory data submissions to the TRI to identify processes and the expected quantity of

chemicals released. For the first time in 2020, MPCA requested that facilities voluntarily submit release

information for five PFAS. Because PFAS have never before been included, MPCA’s understanding of

PFAS air emissions in Minnesota is currently extremely limited.

In addition to voluntary reporting for PFAS, there are some ongoing efforts to monitor for PFAS in the air

in the upper Midwest. Minnesota is currently conducting air monitoring for PFAS at four different

locations in the state. Indiana University is using a $6 million EPA Multi-Purpose Grant (MPG) to launch a

PFAS monitoring effort in the Great Lakes region implemented by the Integrated Atmospheric

Deposition Network.

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More research into PFAS concentrations in air and rainwater would inform

strategies to reduce PFAS loading to the environment.

Challenges to reducing risks associated with PFAS air emissions

All PFAS are either highly persistent or degrade to highly persistent PFAS. Ongoing emissions of PFAS

cause increased loading to the environment, potentially to levels causing adverse health effects in

humans or wildlife. The ability of some PFAS to move long distances in the atmosphere before they are

deposited to the surface means that air emissions could potentially impact soils, surface water, and

other environmental media hundreds of miles away from the original emission site. The ability of a

single facility to pollute a widespread region with these highly persistent compounds makes controlling

PFAS emissions to the atmosphere an important, but challenging, element to any holistic PFAS

management strategy.

One challenge in controlling PFAS emission stems from the lack of EPA-approved stack testing methods

for PFAS and the lack of any air methods that capture the diversity of PFAS being produced or used in

the country today. Though EPA has planned publication of stack emission testing methods for PFAS in

2021, these methods will only include a subset of all PFAS being produced and used in industry or

commerce. There are stack testing methods available that could be used in lieu of the EPA-approved

methods, and these methods are being used in a regulatory context in other states. Many PFAS (such as

the chlorinated PFAS recently discovered in New Jersey soils

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), are considered “confidential business

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MPCA. (2020, Jan 30). Minnesota Pollution Control Agency’s (MPCA’s) comments on the Addition of Certain Per- and

Polyfuoroalkyl Substances; Community Right-to-Know Toxic Chemical Release Reporting (EPA-HQ-TRI-2019-0375). Available

upon request.

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EPA. (2019, September 26). EPA Awards Nearly $6 Million to Indiana University to Monitor Airborne Pollution in the Great

Lakes. [Press release]. Retrieved from https://www.epa.gov/newsreleases/epa-awards-nearly-6-million-indiana-university-

monitor-airborne-pollution-great-lakes

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Washington, J., Rosal, C.G., McCord, J.P., Strynar, M.J., Lindstrom, A.B., Bergman, E.L., Goodrow, S.M., Tadesse, H.K., Pilant,

A.N., Washington, B.J., David, M.J., Stuart, B.G., & Jenkins, T.M. (2020). Non-targeted mass-spectral detection of

chloroperfluoropolyether carboxylates in New Jersey soils. Science, 368, 6495, 1103-1107. Doi: 10.1126/science.aba7127

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information” and researchers are not able to include them in analytical methods for monitoring until

they are first “discovered” using laborious non-targeted analytical techniques.

The widespread inclusion of PFAS in commercial products has led to concerns about PFAS entering the

atmosphere at waste facilities. Some PFAS-containing commercial products are likely incinerated at

trash collecting facilities – because standard incineration procedures are not likely to break the carbon-

fluorine bond in PFAS, PFAS in commercial products could be emitted to the atmosphere. Other PFAS-

containing commercial products are disposed of at landfills, where water-soluble PFAS can leach into the

wastewater (leachate) over time. Procedures used by hazardous waste managers and non-hazardous

landfills to reduce the volume of PFAS-containing leachate through evaporation could also lead to PFAS

being emitted to the atmosphere. Volatile PFAS in waste could be released from landfills or composting

facilities over time. Although PFAS destruction may be possible at high temperature hazardous waste

incineration facilities, without reliable and consistent stack test methods, it can be difficult to conclude if

complete destruction is occurring. There are currently lawsuits related to alleged PFAS contamination

resulting from incineration of PFAS-containing firefighting foams in New York.

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Due to the lack of air

monitoring data and stack emission testing methods, there are many uncertainties about the amount of

PFAS pollution resulting from incineration of PFAS-containing waste or volatilization of PFAS at landfills.

Another challenge related to managing PFAS emissions to air is the lack of information about direct PFAS

toxicity from inhalation. Most PFAS have no publicly available toxicity information for inhalation routes

or other routes of exposure, and little is known about PFAS concentrations in outdoor or indoor air.

Many PFAS are considered “confidential business information” and their structures, uses, and emissions

are not shared with the public. With this dearth of occurrence, environmental fate, and toxicity

information for PFAS in the air, air risk assessment is highly uncertain.

Past and ongoing efforts

Despite the many challenges associated with measuring PFAS in the air and collecting data on PFAS

emissions, Minnesota has undertaken several projects related to PFAS and air exposure. Other projects

to gain a better handle on PFAS and air emissions and deposition are ongoing.

Emissions reporting

Adding Five PFAS to Minnesota Air Emission Inventory for 2020

Facilities with air permits are required to submit an Emission Inventory to the Minnesota Pollution

Control Agency (MPCA) every year for the six CAPs in addition to ammonia, mercury, and greenhouse

gases. Every three years, facilities are also required to report emissions of HAPS to MPCA for inclusion in

the State Air Toxics Database. The upcoming year for emission reporting (2020) is a year that will include

air toxics emission reporting to MPCA. Beginning with the 2020 reporting year, facilities will be

voluntarily asked to submit additional air toxic compounds that are not formally designated as HAPs.

Five of the newly asked for compounds are PFAS: PFOS, PFOA, PFBS, PFHxS, and PFBA.

In addition to reporting their air emissions to the MPCA, facilities also report their emissions to the EPA

via the TRI program. The reporting requirements for TRI are different than the requirements facilities

have for reporting to the state. Starting in 2020, EPA added 172 PFAS to the TRI mandatory reporting

list. Though the TRI reporting is mandatory for all facilities, in general, voluntary emissions reporting to

Minnesota are more detailed than to the TRI program. Minnesota requests reporting on specific

amounts of compound released rather than a range (as is reported for TRI). Minnesota also requests

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Lerner, S. (2020). Toxic PFAS fallout found near incinerator in upstate New York. The Intercept. Retrieved from:

https://theintercept.com/2020/04/28/toxic-pfas-afff-upstate-new-york/

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process-specific emission values rather than aggregated emissions for all processes at the plant. This

detailed information that is voluntarily submitted to MPCA can be compared to the mandatory TRI

reporting results to determine if there are discrepancies.

Work status: completed, will go into effect for the 2020 reporting cycle

Leader: MPCA Environmental Analysis and Outcomes Division, Air Assessment Section.

Benefits: By asking facilities to voluntarily submit data on PFAS emissions, MPCA will have data that

can be used to understand and improve air quality at a state, regional, and national level. This

information will help evaluate health risks and identify areas of concern for environmental justice. In

addition to the voluntary reporting emission inventory reporting, facilities will also be required to

submit emission reporting to the EPA for 172 PFAS under the new TRI rules that go into effect for

2020. This combination of TRI data and more detailed voluntary emission data will help piece

together a more complete picture of total PFAS emissions to air in the state.

Challenges: Because the submission of data on additional air toxics to the state is optional, often

data are incomplete or inaccurate. The data submitted to the MPCA is crosschecked with the TRI

data to identify differences in emissions totals reported or any missing pollutants. Some facilities are

contacted by MPCA to clarify or correct differences in the reporting between the two programs.

Though MPCA is currently only asking for voluntary reporting of five PFAS, it is possible that future

requests will include data on more PFAS, especially volatile PFAS and novel PFAS replacement

chemistries.

Resources: While there will be some additional efforts made to notify facilities of the PFAS and

other air toxic compounds being asked for this year, as well as some additional Quality assurance/

quality control required, the resources needed for MPCA are not expected to be significant.

Ambient air monitoring

Ambient air concentrations and air deposition research project

This year-long ambient air PFAS monitoring project includes the collection of ambient air, wet

deposition, and dry deposition samples at four sites across Minnesota. In this new ambient air

monitoring effort, locations were chosen to increase MPCA’s understanding of PFAS sources and

atmospheric transport. The year-long sample collection effort will additionally increase MPCA’s

understanding of temporal trends and the influence of various weather conditions on PFAS atmospheric

dynamics. One “background” air monitoring site is located in Grand Portage, and three urban sites (St.

Louis Park, Eagan, and Duluth) are located near potential emission sources identified by the

Remediation Division of MPCA, and one known PFAS emission source. Samples are collected at all sites

every two weeks.

Air data for PFAS in the state are extremely limited. Previous air monitoring for PFAS in Minnesota had

been limited to the East Metro, adjacent to local sources such as landfills known to be PFAS waste

disposal sites. Since that prior monitoring effort in 2008, Michigan has developed inhalation health

screening levels for PFOS and PFOA that will help provide a sense of relative risks from direct inhalation

of PFAS.

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In addition, Minnesota’s new water quality criterion for PFOS is low, and may be exceeded

solely through atmospheric deposition of PFAS. Understanding the relative contribution of PFAS loading

to surface waters from atmospheric inputs could help focus regulatory priorities.

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Michigan PFAS Action Response Team. (n.d.) Air quality related issues. Retrieved from:

https://www.michigan.gov/pfasresponse/0,9038,7-365-86704_94366---,00.html

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Work status: ongoing

Leaders: MPCA. Partners: Grand Portage Band of Lake Superior Chippewa, SGS AXYS Analytical

Services.

Benefits: Understanding ambient concentrations of PFAS at background sites and sites adjacent to

sources will help us better understand fate and transport of PFAS, and to clarify the importance of

air transport as a mechanism of environmental contamination of PFAS. If data from this study show

potential harm, either directly via inhalation or indirectly via surface water and fish contamination,

resources can be prioritized to reduce potential health risks to communities. Additionally, this

research on potential air contributions to the environment is useful to regulatory partners in the

Great Lakes region, who have expressed interest in Minnesota’s results.

Challenges: Lack of existing standards or guidance for PFAS in Minnesota makes it difficult to draw

conclusions about potential health risks and difficult to communicate with community partners

eager to know if the levels of PFAS in their air are cause for concern. Lack of air toxics rules or permit

limits mean that if detectable PFAS are measured in air, there will be limited regulatory avenues to

stem the ongoing pollution.

Though this project is fully funded, the results may indicate a need for future and/or ongoing PFAS

monitoring in air. PFAS monitoring in air is more expensive (about twice the cost per sample) and

more complex than monitoring in other media like water. Given that there has been less attention

to monitoring PFAS in air than in other media, determining the most appropriate sampling methods

is also difficult. A monitoring site with electricity and a fence is required in order to deploy a sampler

that will not be tampered with or disturbed and trained staff are needed to operate the samplers.

Any future air monitoring efforts would require additional staff and funding.

Resources: This project is funded by MPCA and an EPA MPG, with a total cost of approximately

$250,000. Though existing MPCA monitoring staff have been able to work on this project, it is

probably not feasible for current staff to do extensive PFAS monitoring in the long-term because

current staff are busy supporting the state’s required air monitoring network.

Gaps and opportunities

There are several key gaps in research and policy related to PFAS and air. Though mandatory PFAS

emission reporting to the EPA through TRI will go into effect for year 2020, exemptions in the TRI

reporting requirements will leave gaps in the PFAS air emission database. Additionally, reporting to the

federal TRI program is not as detailed as toxics reporting to MPCA’s Air Toxics Database. There are

currently no mandatory PFAS reporting requirements for PFAS in Minnesota, which means that MPCA

has limited information available to assess which facilities may be major sources of PFAS. To fill this gap,

MPCA could consider making PFAS reporting mandatory through a rulemaking process. Though PFAS are

not listed as HAPs, a rulemaking for mandatory reporting of air toxics could include mandatory reporting

of PFAS.

Once MPCA has an understanding of which PFAS are being emitted in the state, there are still significant

gaps in our understanding of both direct toxicity of PFAS via inhalation and indirect toxicity caused by

PFAS loading to other environmental media like surface water, fish, game, and soil. The gaps associated

with quantifying direct PFAS inhalation toxicity are discussed in the Quantifying PFAS Risks to Human

Health Issue Paper and are mainly driven by work completed at MDH. However, gaps associated with

gaining an understanding of PFAS dynamics from air to other media fall under the purview of the

MPCA’s Environmental Analysis and Outcomes, Air Modeling, and Water Quality Standards units.

Developing a model that includes cross-media considerations of exposure for persistent and

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bioaccumulative compounds, such as PFAS, could be used to assess PFAS cross-media risks and fill gaps

associated with unknown impacts of loading to the air.

Consider a new rule to make air toxics reporting mandatory, including PFAS

Air toxics emissions reporting by permitted facilities in Minnesota is currently voluntary -- PFAS have not

historically been included in the list of compounds for voluntary toxics reporting. In this proposal,

Minnesota would join the growing list of states (including nearby and Region 5 states like WI, IA, ND, OH,

IL, etc.) that require annual or once every three-year reporting of air toxics by certain permitted facilities

that meet specified reporting requirements. The rulemaking to make this reporting mandatory could

include PFAS in the proposed list of air toxics with required reporting. In the summer of 2020, MPCA

presented a webinar to interested stakeholders explaining the current status of air toxics reporting in

Minnesota, the gaps in the current approach, and the potential new reporting rule that MPCA could put in

place. This presentation and a summary of stakeholder comments is available on MPCA’s website.

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Work status: ongoing

Leader: MPCA Air Policy Unit. Partners: MPCA Emissions Inventory, Risk Evaluation, Small Business

Assistance, and Air Permitting programs.

Benefits: Mandatory air toxics reporting would dramatically improve the emission inventory

information that MPCA receives. This emission inventory information supports achieving MPCA’s

goals of eliminating the state’s disproportionate air pollution impacts and ensuring the quality of

ambient air exceeds health benchmarks. In addition to improving the quality of the air toxics

inventory, mandatory air toxics reporting that includes cross-media pollutants will allow MPCA to

have the data needed to address air emission of pollutants posing a threat to water quality and fish

consumption, including PFOS. The proposed rulemaking would further support MPCA’s strategic

goal to “improve air quality in population centers” by pinpointing the largest emitters of air toxics in

these cities and guiding business assistance programs to target pollutant reductions that provide the

greatest health benefits. This would reduce the emissions and deposition of persistent pollutants,

ultimately improving the air, soil, and water quality throughout the state.

Challenges: Because some PFAS-containing products do not contain labels indicating the PFAS

present, a facility may be using a PFAS-containing product without knowing it, or at least without

knowing the PFAS concentration or composition. This would make it difficult to accurately estimate

emissions. In addition, inventorying PFAS emissions from permitted facilities will not capture all air

releases relevant to Minnesota -- facilities in neighboring states would not be captured unless that

state also requires reporting, and emissions from accidental spills or non-permitted sources within

Minnesota would not be captured. It would also be challenging for MPCA to determine which PFAS

should be included in mandatory reporting requirements. If the proposed rule including mandatory

reporting for all PFAS (the most health-protective and inclusive option), facilities may particularly

need assistance to accurately identify PFAS emissions from less well known PFAS. Just as there are

challenges knowing what PFAS are present in other media, it will be difficult to know which PFAS are

present in air emissions without non-targeted analysis of samples from a given facility. Facilities will

likely be concerned about any new reporting requirements due to the challenges associated with

measuring or estimating PFAS emissions and the administrative challenges associated with

emissions reporting.

Resources: Rulemaking is a time intensive process, with many steps and requirements for agency

staff. In addition to the challenges associated with rulemaking, the first year of implementation

would likely require increased outreach to businesses and additional help from the MPCA Emissions

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MPCA. (n.d.). Potential changes to air toxics reporting. Retrieved from: https://www.pca.state.mn.us/air/potential-changes-

air-toxics-reporting

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Inventory program to assist facilities that are new to emissions reporting. Additional analysis time

would be needed to quality assure and process the increase of emissions data and the number of

facilities reporting.

Require performance testing for PFAS from permitted facilities

Facilities or stationary sources that emit pollutants to the air may be required to obtain an air quality

operating permit. Minnesota issues multiple kinds of air permits, including individual Title V/Part 70

permits, individual state operating permits, capped permits, general permits, and registration permits.

The specific permit required depends on the facility type and its potential to emit air pollutants. Air

quality operating permits routinely include requirements for the facility to conduct performance testing.

Performance testing, also known as stack testing, is a process of measuring the emissions from some or

all of the permitted emission units at the facility. Minnesota rules specify when performance testing

may be required. The MPCA may require testing to quantify the emissions from an emission facility

where the agency has determined a possible environmental or public health concern exists.

Performance testing for PFAS is limited, but available. As described by the Michigan PFAS Action

Response Team,

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“some states have conducted stack testing using a modified US Environmental

Protection Agency (EPA) Method 5. These states include: NY, NH, and NC.” These stack tests focused on

industrial facilities; for instance, New Hampshire in collaboration with EPA has investigated PFAS in air

emissions from a performance plastics facility.

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New York has looked at PFAS air emissions and

deposition from a similar performance plastics facility.

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For stationary source emission sampling and

analysis, EPA Office of Research and Development (ORD) and Air Quality Planning and Standards has

identified an “Other Test Method” for PFAS called “OTM-45: Measurement of Selected Per- and

Polyfluorinated Alkyl Substances from Stationary Sources.” This “other test method” does not have

regulatory status (this test method has not been approved through federal or state rulemaking).

In order to better understand PFAS air emissions, the MPCA could develop a strategy to incorporate

PFAS performance testing into air quality operating permits or compliance documents. Developing and

implementing the strategy would require considering which types of facilities should conduct

performance testing – likely focused on facilities most likely to have PFAS emissions. The strategy would

consider the available performance test methods, which PFAS the test methods detect, and the

necessary performance test frequency.

Leader: MPCA Industrial Division.

Benefits: Understanding sources of PFAS (such as PFAS producing facilities and other industrial

facilities that use PFAS-containing products) and levels of PFAS emitted would help guide future

PFAS reduction strategies. Performance test data could help support understanding of whether

PFAS are destroyed in incinerators, and the feasibility of air emission control technology to control

PFAS emissions. Performance test data could also be used to support future regulations of PFAS uses

or restrictions on PFAS emissions.

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Michigan PFAS Response Team. (n.d.) Air Quality Related Issues. Retrieved from:

https://www.michigan.gov/pfasresponse/0,9038,7-365-86704_94366---,00.html

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New Hampshire Department of Environmental Services (2019, April). 2018 Results for Per-and Polyfluoroalkyl Substances

(PFAS)Analyses Performed by United States Environmental Protection Agency’s Office of Research and Development for

Samples Collected in Southern New Hampshire.

https://www4.des.state.nh.us/OneStopPub/Air/330110016504192019TypeCR.pdf

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New York Department of Environmental Conservation. Hoosick Falls Area

Information for Communities Impacted by Per- and Poly-fluorinated Akyl Substances (PFAS)

https://www.dec.ny.gov/chemical/108791.html

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New York Department of Environmental Conservation. (2020, February 12). Presentation: PFAS Air Emission Testing Results

from Manufacturing Sources. Retrieved from:

https://gflawma.wildapricot.org/resources/Documents/2)%20Thomas%20Gentile%20AWMA%202-12-20.pdf

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Challenges: There is currently no approved stack test methodology that is enforceable. In addition,

current stack testing methods are expensive. Prioritizing which permits should require performance

testing will require research and investigation into currently limited information about PFAS air

emissions and discussion with regulated facilities. The newest set of federal TRI data, data from the

PFAS ambient air monitoring project (see pg. 115), Pilot PFAS Inventory (see the Remediating PFAS

Contaminated Sites Issue Paper ), and mandatory air toxics emissions reporting rule (see pg. 117)

might all provide information to support decisions about which facilities would be likely emitters of

PFAS. The legal soundness of MPCA’s authority to require PFAS performance testing should be well

understood before requiring any testing since permitted facilities and industry groups may challenge

the agency’s authority. The regulatory focus of air permits is on “regulated air pollutants” and

“applicable requirements.”

Resources: MPCA would require moderate to significant staff resources to complete this action.

Explore cross-program air modeling project to understand PFAS air emissions and their

impacts on air, groundwater, surface water, and fish tissue

Information is needed regarding the level of PFAS air emissions that could impair surface water or other

media so that air emissions can be controlled to protect these sensitive endpoints. The EPA developed a

model to estimate deposition of air pollutants onto surfaces (e.g. water, soil) and uptake into the food

chain using chemical-specific parameters.

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This model, called the Human Health Risk Assessment

Protocol (HHRAP), is currently used by the air toxics program at MPCA to assess the fate of persistent,

bioaccumulative, and toxic compounds, including potential cross-media impacts of new projects and

permit amendments. This proposal is to apply the HHRAP to model PFAS movement from air to water

and soil, and subsequent uptake to plants and fish.

Using the HHRAP for PFAS would involve gathering available chemical/physical fate and transport

parameters for PFAS. These include parameters necessary to estimate sorption to water and soil

particles, dissolution in water, uptake into biota, sorption into the organic fraction of soil and water,

bioaccumulation rates, and volatility. If the model were to be refined for use at a specific site, site

characteristics (including source parameters, air emissions, environmental parameters, meteorological

data, topography, and surface water depth and flow near PFAS emitters), would also be collected. Such

a model could be run to understand when limits on PFAS emissions would be needed to protect human

and ecological health.

In order to capture PFAS exposure deriving from precursor compounds, the model could be refined to

incorporate PFAS transformation and breakdown products into emission estimates and air deposition

modeling. This would be accomplished by applying a PFAS precursor model to the direct emissions from

a facility to estimate the products that would eventually be entrained into the air and potentially deposit

onto land and water surfaces.

Work status: under consideration

Leader: MPCA Environmental Analysis and Outcomes Division.

Benefits: Developing this model could allow MPCA to estimate human exposure to PFAS from

multiple routes, including inhalation, surface water, and fish consumption for populations living near

facilities that emit PFAS such as platers, metal processers, and contaminated sites. Facilities and

waste sites tend to be concentrated more heavily in environmental justice communities.

135

Using

134

EPA. (2005). Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities.

https://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P10067PR.TXT

135

Taylor, D. (2014). Toxic Communities. Environmental racism, industrial pollution, and residential mobility. New York: NYU

Press. https://nyupress.org/9781479861781/toxic-communities/

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the modified HHRAP model discussed in this proposal, Minnesota could determine if PFAS emissions

from a facility were contributing to surface water impairments or exceedances of health-based

thresholds for other media like soils. This knowledge could allow MPCA to develop annual emission

reporting limits for PFAS facilities, as has been done in other states like New Hampshire.

136

Challenges: There are several challenges to modifying the HHRAP model to predict PFAS impacts on

multiple media from air emissions. Some PFAS will not have the known fate and transport

parameters required to run the model, and modelers would likely have to rely on computationally

estimated values like those derived by EPA’s CompTox program.

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This effort would likely have to

start by focusing on PFAS with the most data available, such as PFOS, PFOA, PFHxS, and precursor

PFAS that degrade to those compounds.

Resources: Applying the HHRAP for use on PFAS would require multiple staff with chemical fate

transport experience, water quality criteria experience and atmospheric deposition and

bioaccumulation modeling experience. This effort would not require additional authorities, but may

require additional staff.

Overview of intersectional issues

 Fish and game consumption: New assessments of risks posed to human health from surface

water contamination indicate that low levels of bioaccumulative PFAS like PFOS can result in

significant levels of exposure. Protecting fish and game for human consumption may require

limits on PFAS emissions to air that result in PFAS loading to surface water.

 Pollution prevention: Reducing PFAS pollution at the source places the cost burden of

treatment with the polluters. Requiring sources of PFAS emissions to the air to reduce overall air

emissions would take the cost burden away from communities struggling with PFAS

contamination of surface water, drinking water, and food like fish and game.

 Quantifying PFAS toxicity: Understanding of the potential health impacts of PFAS exposure is

key in ensuring exposure stays below “safe” thresholds and communicating with the public.

Health-based guidance values, however, require data on toxicity and exposure that are not

available for the vast majority of all the PFAS found in the environment. See the Quantifying

PFAS Risks to Human Health Issue Paper for more information on challenges stemming from

PFAS toxicity data limitations.

 Managing PFAS in waste streams: Landfill leachate, effluent and biosolids from wastewater

treatment plants, and contact water from composting facilities all contain PFAS stemming from

industrial and commercial uses of PFAS-containing products. Waste management strategies like

burning trash or evaporating landfill leachate could result in additional PFAS emissions to the

air, where they can spread in the atmosphere and cause widespread contamination.

Considerations will be needed to ensure that waste facilities are not emitting PFAS to an extent

that harms human or ecological health.

 Developing and expanding access to analytical methods: Analytical methods for PFAS are

expensive and time-intensive to run, and include only a subset of all PFAS that may be occurring

in surface water and biota. There are currently no EPA-approved methods for testing PFAS at

the stack, though other non-EPA approved air methods are available.

136

Beahm, C. Saint-Gobain Performance Plastics air permit public hearing. [PowerPoint slides] Retrieved from:

https://www4.des.state.nh.us/nh-pfas-investigation/wp-content/uploads/SGPP-Draft-Air-Permit-Public-Hearing-

Presentation_11052019.pdf

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EPA. (n.d.). CompTox Chemicals Dashboard. Retrieved from: https://comptox.epa.gov/dashboard

Minnesota’s PFAS Blueprint • February 2021

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Background

 Minnesotans value having healthy, diverse ecosystems – protecting the environment includes

protecting wildlife like birds, mammals, plants, and aquatic organisms against harmful pollution.

 Efforts related to PFAS pollution in Minnesota have historically focused on protection of human

health, but there has been ongoing research into potential ecological impacts from PFAS

contamination since the early 2000s.

 Ecological risk assessments establish levels of a contaminant in various ecological media that are

unlikely to result in adverse impacts – the risk-based values derived in these assessments could be

relevant to multiple sites.

 EPA, Environment and Climate Change Canada (ECCC), MPCA, and other state agencies have

conducted ecological risk assessments. For PFAS, ECCC has published an assessment for PFOS, and

EPA has similar assessments underway for PFOA and PFOS.

 MPCA Remediation Division programs’ site investigations are conducted to determine the likelihood for

adverse ecological effects. These investigations use risk-based values derived in ecological risk

assessments, when available for PFAS, to compare against levels seen at the site. These risk-based

values for ecological endpoints may be additionally used as clean-up values.

 MPCA also conducts ecological risk assessments as part of standard or criteria development under the

Clean Water Act (CWA). The CWA is a federal law that allows states to protect surface waters by

determining the beneficial uses of the waterbody and setting water quality standards (WQS) to protect

those uses. Beneficial uses for waterbodies include sustaining aquatic life (fish, aquatic insects, and

aquatic-dependent wildlife).

 Deriving WQS protective of aquatic life and aquatic-dependent wildlife is generally not prioritized if

values protective of other endpoints, like human health, would likely result in more protective

WQS than those for aquatic life.

 Should EPA publish the ecological risk assessment and corresponding recommended aquatic life

criteria for PFOA and PFOS, MPCA would consider adopting those recommended criteria into

Minnesota’s WQSs.

 There are many challenges to conducting ecological risk assessments for PFAS.

 With over 5,000 known structures in the PFAS family, there are not ecological toxicity data for

the vast majority of PFAS that may be found in the environment.

 For PFAS with ecological data available, conducting risk assessments using CWA methodologies

requires significant time from skilled staff.

 Outside of the CWA methodologies for conducing risk assessment for aquatic life, there are

not MPCA methods available for risk assessments that derive risk-based values protective of

mammals or other non-aquatic wildlife that could be impacted by PFAS releases to land or

water.

 New methods for ecological risk assessment that rely on computational models or other predictive

tools designed for the unique physical and chemical properties of PFAS are in development. These new

computational methods could be an important resource for PFAS ecological risk assessment moving

forward.

Protecting ecosystem health

Summary

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What is Minnesota doing now?

 MPCA has developed site-specific WQC protective of aquatic life under the CWA for PFOA and PFOS in

Pool 2 of the Mississippi River.

 Minnesota has completed or provided funding for multiple monitoring efforts for PFAS in various

ecological receptors.

 MPCA monitored for PFAS in benthic invertebrates, which are important components of the

aquatic food chain, along with fish, water, and sediment in Pool 2 of the Mississippi River. This data

informed knowledge of PFAS transfer from sediment and water into biota.

 MPCA provided funding for two separate studies monitoring PFAS in birds. One study measured

PFAS levels in eggs of tree swallows nesting in Minnesota and Wisconsin and found that increased

PFAS levels were associated with decreases in reproductive success. Another study monitored for

PFAS in the blood of Bald Eagle nestlings in Minnesota.

 MPCA is currently conducting analysis of PFAS levels in aquatic animals, sediment, and surface

water as part of the work in the East Metro Area.

What are remaining gaps and opportunities for action?

 Gap: There is a lack of completed risk assessments for ecological health endpoints. The existing risk

assessments that derived risk-based values for PFOA and PFOS protective of aquatic life in the

Mississippi River were completed before new ecological toxicity data became available from federal

agencies and academic researchers. Other PFAS do not have risk-based values available for use in

WQS, Water Quality Criteria (WQC), or site assessment under the Superfund program.

 Opportunity: The Aquatic Toxicity Profile (ATP) is a tool developed by MPCA to understand

potential impacts of contaminants of emerging concern in the environment. MPCA could complete

ATPs for as many PFAS as possible to prioritize complete risk assessment using CWA

methodologies.

 Opportunity: PFAS data collected by MPCA, MDNR, other state agencies, the EPA and international

agencies like ECCC could be used to develop ecological risk screening values relevant to all local

wildlife, not just aquatic organisms. These values would help guide clean-up efforts and inform the

need for standards under the CWA.

 Opportunity: Recent studies of what appeared to be naturally-occurring foams on surface water

have revealed they contain high concentrations of PFAS. MPCA could investigate if PFAS-containing

foam is causing acute ecological toxicity.

How does this work benefit human health and the environment?

 Conducting ecological risk assessment and site investigations provide the information needed to

determine if there is potential for PFAS releases to cause adverse effects in wildlife, and react

appropriately to protect those species.

 Healthy ecosystems improve the mental health and wellbeing of all Minnesotans.

How does this work benefit Minnesota’s economy?

 Healthy ecosystems provide opportunities for tourism and provide a strong basis for industries that

rely on ecosystem services like abundant fish and wildlife.

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Background

Minnesotans value having healthy, diverse ecosystems – protecting the environment includes protecting

wildlife like birds, mammals, plants, and aquatic organisms against harmful pollution. Though initial

research on PFAS pollution in Minnesota focused on protection of human health, there has been ongoing

research and risk assessment related to ecological health since the early 2000s. This issue paper aims to

introduce the science behind ecological risk assessment and the regulatory tools and structures available

to protect wildlife, outline the past and ongoing work to study ecological impacts of PFAS in the state, and

finally discuss the gaps and opportunities remaining in the area of PFAS ecological risk assessment.

Ecological risk assessment

Ecological risk assessments determine levels of contaminants in various media (such as water, soil,

sediment) that are unlikely to result in adverse ecological effects in aquatic life or aquatic-dependent

wildlife. These values are used to develop WQS, which prevent discharges to surface water at

concentrations that would pose risks to ecological health. Under the Superfund program, site

assessments estimate the likelihood that adverse ecological effects are occurring at the site. These site

assessments are used to identify and characterize the current or potential threats to the environment,

to evaluate the ecological impacts of various remediation strategies, and to establish clean-up levels in

the selected strategy that will protect wildlife at risk. Ecological site assessments often rely on risk

assessments that have derived risk-based values for comparison to levels seen in samples collected from

the contaminated site.

Ecological risk assessments consider several potential avenues for disruption to ecosystems. One

mechanism for ecosystem harm is direct toxicity to wildlife or plants from exposure to the compound.

Direct toxic effects are generally determined by conducting laboratory toxicity studies where various

organisms are exposed to controlled concentrations of the substance to determine lethal concentrations

or concentrations likely to produce other toxic effects. However, ecological risk assessments can also

include consideration of toxic effects associated with bioaccumulation of the substance in an organism

over time, which could potentially lead to effects not observed in direct toxicity studies.

Bioaccumulation factors – which are a numeric value for how much a pollutant accumulates from the

environment into biological tissues -- can be determined by measuring concentrations in environmental

media (like water or soil) and concentrations in biological samples (like fish or mammals). Finally,

ecological risk assessments can also consider trophic transfer through food chains to capture scenarios

when concentrations accumulate in predator organisms, which is called food chain biomagnification.

Trophic transfer factors can be calculated by comparing biological samples from various trophic levels.

After considering direct toxicity, bioaccumulation, and biomagnification, assessments will determine

which concentrations of the substance should not result in adverse ecosystem effects when observed in

various media like surface water, sediment, fish tissue, blood of predator species, or eggs of birds.

There are several databases and tools that are frequently used to help develop ecological risk

assessments. The ECOTOXicology knowledgebase (ECOTOX) is a tool developed and maintained by the

EPA that provides a searchable database for environmental toxicity data on aquatic life, terrestrial plants

and wildlife. There has been a concerted effort by EPA to regularly conduct literature searches for PFAS,

extract the reported data, and upload that data into ECOTOX. EPA researchers are also producing data

from conducting their own studies on ecological toxicity due to PFAS exposure, which are also being

loaded into ECOTOX. In all, this database is useful for identifying susceptible species, understanding

bioaccumulation, and supporting decisions to protect ecosystems. MPCA and DNR have also collected

biological samples for analysis, contributing to a local database of PFAS data in wildlife. In addition to

ECOTOX and state-collected data, EPA is continuing to develop predictive models for determining

toxicity, bioaccumulation, and various physical and chemical properties for PFAS. The results of some of

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these models are available on the EPA’s Chemistry Dashboard, where the results of the predictive model

OPERA can be downloaded.

138

139

These predictive models are especially useful for screening level

assessments in scenarios where ecological data for the PFAS in question are not available.

Though data limitations have hindered efforts to conduct ecological risk assessments for most PFAS,

Minnesota has conducted past site-specific aquatic life risk assessments for PFOA and PFOS for Bde

Maka Ska (formerly, Lake Calhoun) and Pool 2 of the Mississippi River,

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and is currently conducting a

site-specific ecological risk assessment for PFAS in the East Metro (the Project 1007 Corridor). In

addition, Environment and Climate Change Canada has published an ecological risk assessment deriving

Federal Wildlife Dietary Guidelines, which include health-protective levels designed to protect

mammalian and avian consumers of aquatic biota, for PFOS.

141

Currently, there are not risk assessments

available for terrestrial ecosystem health; however, some state agencies, like Michigan EGLE, are

starting field investigations including risks of PFAS to muskrats in Clark’s Marsh.

142

Finally, in 2019, the

National Wildlife Foundation published a report on the existing research related to PFAS occurrence and

effects on wildlife in the Great Lakes Region, which includes a summary of potential policy actions

available for protecting wildlife moving forward.

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Regulatory structures for protection of ecological health

The DNR and MPCA both participate in monitoring wildlife, but the regulatory authority for protecting

ecological health against chemical contamination health rests with the MPCA. The CWA is a federal law

that allows states to protect surface waters by determining the “beneficial uses” of the

waterbody and setting WQS to protect those uses. States monitor waterbodies to compare levels of

pollution to the applicable standards and list waterbodies as “impaired” if they exceed the WQS and

therefore do not meet their beneficial uses. States also permit facilities that discharge into surface

waters in order to ensure that their discharges do not have the reasonable potential to cause or

contribute to an exceedance of any WQS.

Beneficial uses for waterbodies include aquatic life, which means protecting the health of aquatic

communities (such as fish and aquatic insects) and aquatic-dependent wildlife. In the context of CWA

implementation, MPCA has conducted site-specific risk assessments for PFOA and PFOS protective of

aquatic life, but has not generated a state-wide standard protective of aquatic life or aquatic-dependent

wildlife. Deriving new standards protective of aquatic life and aquatic-dependent wildlife for a given

contaminant is generally not prioritized if standards protective of other endpoints, like human health

due to consuming fish or drinking water, would likely result in more protective standards than those

protective of wildlife.

In addition to MPCA’s regulatory authorities over aquatic life protections in surface waters, the agency

also has regulatory authority to require clean-ups of terrestrial sites that may have contamination

138

EPA. (n.d.) CompTox Chemicals Dashboard. https://comptox.epa.gov/dashboard/

139

Lampic, A. & Parnic, M.J. (2020). Property estimation of per- and polyfluoroalkyl substances: a comparative assessment of

estimation methods. Environmental Chemistry, 39, 4, 775-786. DOI: 10.1002/etc.4681

140

MPCA. (2007). Surface Water Quality Criterion for Perfluorooctane Sulfonic Acid. Retrieved from:

https://www.pca.state.mn.us/sites/default/files/pfos-report.pdf; MPCA. (2007).Surface Water Quality Criterion for

Perfluorooctanic Acid. Retrieved from: https://www.pca.state.mn.us/sites/default/files/pfoa-report.pdf

141

ECCC. (2019). Canadian Environmental Protection Act, 1999 Federal Environmental Quality Guidelines Perfluorooctane

Sulfonate. https://www.canada.ca/en/environment-climate-change/services/evaluating-existing-substances/federal-

environmental-quality-guidelines-perfluorooctane-sulfonate.html#toc11

142

MI Department of Health and Human Services. (2019). Public Health Advisory for Wildlife from Clark’s Marsh. [Memo].

Retrieved from: https://www.dhd2.org/wp-content/uploads/2019/12/APPROVED-Clarks-Marsh-Memo_Do-Not-Eat-Wildlife.pdf

143

Murray, M.W., & Salim, O. (2019). The Science and Policy of PFAS in the Great Lakes Region: A Roadmap for Local, State and

Federal Action, National Wildlife Federation, Great Lakes Regional Center, Ann Arbor, MI. National Wildlife Federation.

Retrieved from: www.nwf.org/-/media/Documents/PDFs/NWF-Reports/2019/NWF-PFAS-Great-Lakes-Region.ashx

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impacting human health and aquatic or terrestrial ecosystems. These authorities fall under the federal

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly referred

to as “Superfund,” and the state Minnesota Environmental Response and Liability Act (MERLA) laws.

CERCLA is the federal law that governs how locations with released hazardous substances are identified,

prioritized, and ultimately cleaned up. MERLA, found in Minn. Stat. 115B, establishes the state

Superfund Program. This law provides broad state authority to respond to releases or threatened

releases of hazardous substances that may endanger public health, welfare, or the environment. Sites

with significant contamination warranting placement on the National Priorities List under CERCLA are

managed in partnership with the federal EPA, but many other sites are managed by MPCA under the

state version of the Superfund law.

Though there are several available documented methodologies for conducting ecological risk

assessments in aquatic ecosystems, methodologies for conducting ecological risk assessments for

terrestrial ecosystems are limited. This is partially because environmental regulations like the CWA

allows for regulation of discharges of chemicals to water that may cause harm to aquatic life, but similar

regulations investigating and remediating discharges of chemicals to land, like CERCLA and MERLA, are

more focused on assessing risks to humans than to wildlife. For example, when new sites are being

investigated for possible remediation under Superfund, visual inspections for dead vegetation or

animals are conducted, but generally not detailed risk assessments considering ecological endpoints –

clean-up standards derived for human health protection are often assumed to also be protective of

terrestrial ecological health. Progress towards filling the gap in terrestrial risk assessment could be made

by establishing terrestrial risk assessment methodologies appropriate for conducting these assessments

for PFAS.

Challenges to conducting ecological risk assessment for PFAS

There are many challenges to conducting ecological risk assessments for PFAS. Firstly, with over 5,000

known structures in the PFAS family, there simply is not toxicity, bioaccumulation, or biomagnification

data for the vast majority of PFAS that may be found in the environment. Data collection and risk

assessment for these compounds are generally prioritized first towards human health rather than

ecological health. There are available analytical methods to quantify levels of PFAS in biological

specimens, water, soil and sediments for about 40 PFAS, but there may be other PFAS present in the

environment at levels of concern that are not included in regular analysis. When PFAS can be measured,

sample analysis is expensive, ranging from $300-$400 per sample. Because many ecological risk

assessments are inherently site-specific – they consider food chains and species that are relevant to the

potentially contaminated site – site-specific data collection is sometimes warranted. This results in

added costs. Finally, many traditional risk assessments consider effects that are obvious to researchers

without need for additional investigation (frank effects), like lethality, decreases in reproduction, or

clear changes in animal behavior. These effects may not be the most sensitive toxic effects for the

organisms. More sophisticated toxicity studies that consider sensitive effects would result in more

protective risk assessment results.

Despite these challenges, there are ecological risk assessments for PFOS published by the Canadian

agency ECCC that demonstrate what levels of PFOS must be met to protect aquatic life and aquatic-

dependent wildlife, and similar risk assessments are underway at the EPA. There are additionally new

methods for risk assessment that rely on computational models or other predictive tools designed

specifically for the unique physical and chemical properties of PFAS. These new computational methods

could be an important resource for PFAS risk ecological risk assessment moving forward.

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Past and ongoing efforts

The following sections describe the work that has already been completed to better understand and

quantify risks to aquatic life and other ecological systems from PFAS stressors. These sections also

highlight projects that are currently underway at the agency.

Monitoring and site assessment

Monitored for PFAS in benthic invertebrates in Pool 2 of the Mississippi River

Benthic invertebrates – organisms that live in the sediment of waterbodies – are a foundation of aquatic

ecosystem food webs. They are also especially vulnerable to contaminants that accumulate in aquatic

sediments. Mississippi River Pool 2 is the 32.5-mile reach of the Mississippi between Lock & Dam No. 1

(Ford Dam) and Lock & Dam No. 2 (Hastings Dam) that runs through Minneapolis, St. Paul, and

communities south of St. Paul to Hastings. The 3M Cottage Grove Center has produced and discharged

PFAS into the lower reach of Pool 2 since the 1950s. An extensive collection of fish and water

throughout Pool 2 was completed in 2009, and the sampling was repeated in 2012 and expanded to

include sediment and zoobenthos (also called benthic macroinvertebrates).

The results of the sediment and zoobenthos monitoring in Pool 2 of the Mississippi were variable. The

zoobenthos were sufficiently abundant at 39 of the 50 sediment stations where PFAS analysis was

conducted. PFOS concentrations in the zoobenthos ranged from 2 ng/g-wet weight (ww) to 684 ng/g-

ww, with a median of 12 ng/g-ww. The two samples with the highest PFOS concentrations were both

collected immediately downstream of the 3M Cottage Grove Center. The sediment and invertebrate

PFOS concentrations corroborated previous data of PFAS in fish and water, which showed that highest

concentrations of PFOS were near and downstream of the wastewater discharge outlet of the 3M

Cottage Grove Center. Longer-chain PFAS (nine carbon and greater), which are typically not measurable

in water due to their low solubility, were detected in fish and in sediment. Overall, the flow of PFAS from

sediment to zoobenthos to fish is an important pathway for fish exposure and deserves additional

attention. This indicates that even if a given PFAS is not very soluble in water and not measured in most

ambient water samples, it is still a source of concern in the ecosystem if discharged via effluent to

waterbodies.

Work status: completed, additional studies would be valuable

Leaders: MPCA Water Assessment Section, MPCA Environmental Analysis and Outcomes Division

and the Interagency Fish Contaminant Monitoring Program (includes staff from MPCA, DNR, and

MDH). Partners: DNR Fish and Wildlife Division.

Benefits: Before this study was conducted, there had been limited data available on exposure

pathways to PFAS in aquatic ecosystems. By understanding the pathways of exposure of fish and

other aquatic organisms to various PFAS, MPCA can target our regulatory and research work to

successfully reduce PFAS exposure to fish and other wildlife. The increased understanding about

which PFAS are most likely to stay in sediment is especially interesting and motivates additional

studies on this topic.

Challenges: Collecting zoobenthos is time intensive and unpredictable. Multiple sediments samples

were collected at each site and the zoobenthos had to be sorted from the sediment immediately.

This study observed only one reach of the Mississippi at one period of time – additional studies of

lakes and rivers in Minnesota would be beneficial and continue to add to our understanding of PFAS

impacts on aquatic food webs.

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Resources: This project required funding for analytical sampling (~$50,000) and a field crew (four

people for one week). Additional efforts to pair zoobenthos and sediment PFAS sampling would help

inform ecological risk assessments, especially for PFAS likely to occur in sediment rather than water.

Providing funding to research partners for monitoring and effects analysis for PFAS in birds

Concerns over the health of birds who may be exposed to PFAS from either fish consumption or aquatic

insect consumption led to MPCA contributing funding for others to conduct research on PFAS levels in

birds and their eggs. In 2008 and 2009, MPCA contributed to funding for a National Park Service study

on levels of persistent compounds, including PFAS, in bald eagle nestlings at three national parks in the

Upper Midwest. This study found that PFAS were detectable in all eaglet plasma samples, with PFOS

contributing the most to the total PFAS concentrations.

144

PFOS was found in high levels in eagles in the

lower St. Croix River and in Mississippi National River and Recreation Area (1,580 µg/L and 1,250 µg/L,

respectively). The second most prevalent PFAS was PFDS (perfluorodecane sulfonic acid), which

contributed significantly to the total PFAS concentration in the Mississippi National River and Recreation

Area eaglets (representing 26% of total PFAS measured), but not in the Lake Superior eaglets

(represented <1% of total PFAS measured). These studies were not designed to assess the

correspondence between PFAS levels and health outcomes in the birds.

A separate study conducted from 2007 to 2011, funded in part by MPCA, focused on PFAS levels and

effects on tree swallows, which gather a large portion of their diet from feeding on insects. The results

of this study were published in the peer-reviewed journal Archives of Environmental Contamination and

Toxicology.

145

This study measured PFAS levels in one egg from tree swallow nests collected from eight

locations in Minnesota and Wisconsin. The study tracked the success of the remaining eggs in the nests

to determine if PFAS levels in the eggs were associated with decreased success in reproduction. The

study found that when PFOS levels in eggs were higher, there was a significant decreased likelihood of

hatchling success.

Work status: completed

Leaders: National Park Service and Academic Partners, with funding from MPCA.

Benefits: This research is beneficial because it could provide part of the basis for ecological risk

assessments and potentially water quality standards protective of aquatic-dependent organisms.

Field-based data for PFAS effects analysis is limited, and these studies being conducted in Minnesota

and other Great Lakes States ensures that they are relevant to local ecological conditions.

Challenges: As MPCA was able to provide funding for this research rather than conducting the

research in the agency, challenges for MPCA were limited.

Resources: The MPCA contributed $50,000 for research on PFAS in swallows and significant funding

for the National Park Service Bald Eagle study.

Conducting site-specific investigation of aquatic life and aquatic-dependent wildlife exposure to PFAS

in the Project 1007 remediation corridor

Project 1007 is a stormwater conveyance system that was constructed by the Valley Branch Watershed

District in the eastern Twin Cities Metro Area (the East Metro). The system was designed to mitigate

flooding in the Tri-Lakes area by lowering water levels in several lakes, but the system also drained the

144

Route, B., Rasmussen, P., Key, R., Meyer, M., & Martell, M. (2011). Spatial Patterns of Persistent Contaminants in Bald Eagle

Nestlings at Three National Parks in the Upper Midwest. Natural Resource Technical Report. Retrieved from:

https://www.nps.gov/miss/learn/nature/upload/BaldEagleContaminants_Route_2011.pdf

145

Custer, C.M., Custer, T.W., Dummer, P.M., Etterson, M.A., Thogmartin, W.E., Wu, Q., Kannan, K., Trowbridge, A., & McKann,

P.C. (2014). Exposure and Effects of Perfluoroalkyl Substances in Tree Swallows Nesting in Minnesota and Wisconsin, USA.

Environmental Contamination and Toxicology, 66, 120-138. DOI 10.1007/s00244-013-9934-0

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wetlands immediately around a disposal site in Oakdale where 3M historically disposed of PFAS waste

(see Remediating PFAS-contaminated Sites Issue Paper). Due to the potential risks to wildlife in this

region posed by elevated PFAS concentrations, MPCA is currently conducting a baseline ecological site

investigation. The goal of the site investigation was to identify risks to wildlife receptors (i.e., fish and

invertebrates) due to exposure to 33 PFAS, including PFOS and PFOA, in surface water and sediment.

Part of this risk assessment includes updating bioaccumulation factors for PFAS from water, soil, and

sediment into wildlife. These uptake factors could be used to inform clean-up values protective of

ecological health in the future. This assessment also includes sampling of PFAS-containing surface water

foam, which may be an important exposure pathway of PFAS to wildlife. A parallel wildlife monitoring

effort near the Project 1007 Corridor for deer is being conducted by the Minnesota Department of

Natural Resources (DNR) (see the Reducing PFAS exposure from Fish and Game Consumption Issue

Paper).

Work status: ongoing

Leaders: MPCA Remediation Division. Partners: MPCA Environmental Analysis and Outcomes

Division, state contractors.

Benefits: Establishing the risks to ecological receptors is an important step towards remediating

PFAS pollution and protecting potentially-impacted wildlife. The data collected as part of the

ecological risk assessment for this site may be relevant to other areas in the state and could possibly

contribute to the development of water quality standards protective of aquatic life or aquatic-

dependent wildlife in the future.

Challenges: Despite much progress in understanding the impacts of PFAS to wildlife, funding for

studies of wildlife health have been more limited than studies of PFAS impacts on human health. As

a result, there are still many data gaps remaining on how PFAS may be impacting ecological systems.

Resources: This risk assessment has been primarily conducted by state contractors, overseen by

MPCA staff. Though this project is ongoing, it is estimated that the sample collection, sample

analysis, and risk assessment effort will cost ~$500,000.

Regulation

Derived site-specific PFOA and PFOS Water Quality Criteria protective of aquatic life for Pool 2 of the

Mississippi River

Site-specific (WQC) are values derived for contaminants present in select waterbodies to protect the

specific Class 2 beneficial uses of that waterbody. These WQC are different from WQS in that they are

derived using authorities already in state rule, not promulgated through a state rulemaking process.

They are applied to specific waterbodies. WQC are developed based on methods and authorities in state

statute and the federal CWA.

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WQC can be derived to protect human health, aquatic life, aquatic

plants, and aquatic-dependent wildlife.

In 2007, after a discovery of significant PFAS releases into the Mississippi River, staff from MPCA’s Water

Quality Standards unit worked with consultants to derive a site-specific WQC protective of aquatic life

for Pool 2 of the Mississippi River. This effort coincided with similar efforts to derive WQC protective of

human health for the same stretch of the river. Though multiple PFAS were measured in river water,

data limitations for most PFAS resulted in prioritizing development of WQC for PFOS, PFOA, and PFBS.

After initial data review and derivations of preliminary criteria, it was determined that, despite some

146

Minnesota Administrative rules. CHAPTER 7050, WATERS OF THE STATE. Retrieved from:

https://www.revisor.mn.gov/rules/7050/?view=chapter

Minnesota’s PFAS Blueprint • February 2021

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data limitations, PFBS did not appear toxic enough to aquatic life to warrant derivation of an aquatic life

WQC. Therefore, MPCA and consultant staff focused on developing aquatic life WQC for PFOA and PFOS.

Minnesota rules outline two methods for developing aquatic life criteria, called Tier 1 and Tier 2

methods, that differ in the amount of data required for each approach. Tier 1 methods are the preferred

approach, but require a larger number of toxicity studies than Tier 2 methods. If the compound does not

meet the minimum data requirements for Tier 2 methods, there is too much uncertainty in the

understanding of toxicity to develop aquatic life criteria. After reviewing the data available, it was

determined that neither PFOA nor PFOS had enough toxicity studies available to qualify for Tier 1

methods, but both qualified for Tier 2 methods. The final chronic criteria (protecting longer-term

exposure) for PFOS and PFOA were calculated as 19 µg/L (1.9 x 10

ng/L) and 1,700 µg/L (1.7 x 10

ng/L),

respectively.

147

148

This assessment also derived acute criteria, protecting short-term exposure, for PFOS

and PFOA of 85 µg/L (8.5 x 10

ng/L) and 15,000 µg/L (1.5 x 10

ng/L), respectively. Because these

chronic and acute values were significantly higher than the respective WQC derived to protect human

health consumption of fish, any clean-up levels or permit limits for this waterbody would have to meet

the human health WQC and subsequently also protect aquatic life. However, the reports that detail the

derivation of these values note that these criteria were derived based on a very limited dataset – as

more data become available, these values should be reassessed to ensure that they can still be

considered protective. This effort did not consider potential toxicity to aquatic-dependent wildlife.

Work status: completed, consideration of new data may warrant updates to existing criteria

Leader: MPCA Environmental Analysis and Outcomes Division.

Benefits: There were several benefits to conducting a risk assessment for aquatic life exposed to

PFOA and PFOS. This effort indicated that risks to aquatic life were less sensitive to PFOA and PFOS

pollution than humans, meaning that cleaning up PFOA and PFOS pollution to levels safe for humans

would also benefit and protect aquatic organisms.

Challenges: At the time that these risk assessments were conducted, there were a very limited

amount of data available regarding aquatic toxicity to PFAS and potential toxicity to aquatic-

dependent wildlife like birds. Because of these limitations, it is not possible to determine with

certainty that the criteria developed are protective of Minnesota wildlife. Additionally, research into

potential impacts to wildlife from PFAS-containing foams that can form on contaminated waterways

continues to evolve. Revisiting ecological risk assessment periodically as more information becomes

available will be important to ensure that these values continue to reflect the best current science.

Resources: The initial effort to develop site-specific water quality criteria for aquatic life in Pool 2 of

the Mississippi involved several MPCA staff and consultant support. The site-specific criteria for Pool

2 of the Mississippi could be updated leveraging ongoing work in the Project 1007 Corridor.

Gaps and opportunities

There are many gaps in data availability and risk assessment, which impact the development of policy

and regulation to protect ecological health from PFAS. PFAS are all either persistent themselves, or

transform to other PFAS that are environmentally persistent. This means that if there continues to be

use and release of PFAS into the environment, levels in environmental media will increase over time,

perhaps reaching levels that are harmful to humans or wildlife. Reducing PFAS loading into the

147

MPCA. (2007).Surface Water Quality Criterion for Perfluorooctane Sulfonic Acid. Retrieved from:

https://www.pca.state.mn.us/sites/default/files/pfos-report.pdf

148

MPCA. (2007).Surface Water Quality Criterion for Perfluorooctanic Acid. Retrieved from:

https://www.pca.state.mn.us/sites/default/files/pfoa-report.pdf

Minnesota’s PFAS Blueprint • February 2021

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environment would be the most protective and effective approach to protecting wildlife (See the

Preventing PFAS Pollution Issue Paper).

To date, most monitoring and risk assessment related to PFAS has been conducted with an eye towards

human health protections. For example, many studies of PFAS in fish tissue focused on measuring fish

fillets – the part of the fish usually eaten by people – rather than the whole fish as it is consumed by

wildlife. However, despite the prioritization of human health research, there have been significant gains

in understanding toxicity to wildlife, bioaccumulation, trophic transfer, and overall contaminant

presence in a large number of species for some PFAS. Combined with advances in computational toxicity

estimation tools from efforts like EPA’s CompTox program,

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these new PFAS wildlife toxicity and

monitoring data provide a sufficient basis to conduct preliminary ecological risk assessments for the

better-studied PFAS like PFOA and PFOS.

For aquatic life, MPCA already has a methodology in place to conduct preliminary toxicity reviews called

ATPs. Conducting ATPs for as many PFAS as possible given data restrictions would help prioritize

development of CWA standards protective of these ecological endpoints. Additionally, ATP completion

could identify scenarios where site-specific ecological risk assessments for clean-up of PFAS

contaminated sites under MERLA or CERLA are warranted.

Though there are methodologies in place at MPCA to conduct reviews of toxicants and impacts on

aquatic ecosystem health, no such methods currently exist for developing risk-based values applicable

to terrestrial ecosystems. Developing these methodologies and implementing them for the data-rich

PFAS could additionally inform the need for site-specific risk assessments at contaminated sites in the

Superfund program or to motivate the development of CWA standards designed to protect aquatic-

dependent wildlife like waterfowl. Currently, DNR is conducting a pilot study of PFAS in deer and

working with MDH and MPCA to determine if surface water impacts are resulting in deer tissue levels

that are of concern for human consumption (see the Reducing PFAS exposure from Fish and Game

Consumption Issue Paper). In collaboration with DNR, MPCA could leverage the PFAS data collected in

these studies to conduct preliminary risk assessments for PFAS accumulation in terrestrial ecosystems.

In addition to opportunities to conduct risk assessment for ecosystem impacts due to PFAS

contamination in soil, sediment and water, there is an additional gap in understanding of a new PFAS

phenomenon observed on surface water – PFAS-enriched foams. Recent monitoring of PFAS-rich foams

in Minnesota and other states in the Upper Midwest have revealed that these foams preferentially

accumulate PFAS that are designed to act as surfactants (like PFOA, PFOS, PFHxS, and many others).

Concentrations of PFAS in these foams have proven to be exceptionally high -- upwards of 20 ppm

(20,000,000 ng PFOS per liter of foam). MPCA and MDH have issued guidance for people not to touch

surface water foams while recreating.

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The potential risks of these PFAS-enriched foams to wildlife are

unknown. The Great Lakes PFAS Taskforce, an interagency taskforce of governments from the US and

Canada in states and provinces bordering the Great Lakes, has created a specialized sub-team of experts

to share data on PFAS-enriched surface water foams. In order to continue advancing our understanding

of potential risks posed by these foams, MPCA could compile the existing information and assess the

ability to conduct acute-risk assessments for wildlife exposure to PFAS-rich foam.

149

EPA. CompTox Chemistry Dashboard. https://comptox.epa.gov/dashboard/

150

MPCA. (n.d.). PFAS foam on surface water. Retrieved from: https://www.pca.state.mn.us/waste/pfas-foam-surface-water

Minnesota’s PFAS Blueprint • February 2021

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Risk assessment

Conduct Aquatic Toxicity Profiles for PFAS to assess the need to update aquatic life criteria or develop

statewide aquatic life standards

In 2017, MPCA developed new methods —Aquatic Toxicity Profiles (ATPs) — to help understand how

various contaminants of emerging concern in the environment might be impacting wildlife. ATPs use a

weight-of-evidence approach to gain a broad understanding of the potential impacts of specific

contaminants in the environment. ATPs help MPCA prioritize contaminants for further toxicity or

occurrence research. Some ATPs have been completed for PFAS. Each ATP consists of two parts, a

worksheet containing all the technical information used to determine the level of concern of each

contaminant and a summary profile that gives a brief overview of the concerns related to each

contaminant. This proposal is to conduct ATPs for as many PFAS as there are data (modeled or

empirical) available.

Work status: under consideration

Leader: MPCA Environmental Analysis and Outcomes Division, Water Quality Standards Unit.

Benefits: This effort would be beneficial for several reasons. Firstly, the results of ATP screening

would prioritize which PFAS observed in the environment have data available for developing aquatic

life standards and which PFAS may have high toxicity risk and would be good candidates for further

research.

Challenges: Data generated by governments are often published in reports rather than peer-

reviewed academic journals. As a result, they are often not included in databases used for literature

reviews for an ATP, such as ECOTOX. Modeled data can be used if the model was designed to reflect

the unique physical and chemical traits of the PFAS class of compounds.

Resources: This effort would not require additional funding, but may benefit from contractor

support. Staff time would be needed to compile data and complete ATPs. Collaboration with

partners within Minnesota, in the EPA, and in the Great Lakes PFAS Taskforce might be beneficial.

Leverage data from existing studies to develop state-wide wildlife risk values for PFAS

Various studies of PFAS accumulation in deer, waterfowl and other wildlife have been undertaken by

state governments in the US and internationally. In Minnesota, the DNR is currently collecting deer

samples for PFAS analysis in regions of the state with known surface water PFAS contamination. Though

the main goal of this study is to ensure that game harvested for consumption by humans is safe to eat,

the data collected will also help inform ecological risk assessments for terrestrial wildlife. Other

agencies, including Environment and Climate Change Canada, have developed environmental quality

guidelines that are designed to provide thresholds for concern of PFAS in various wildlife, including PFAS

levels in bird eggs. Additionally, an effort to assess wildlife impacts at the Project 1007 Corridor PFAS

remediation site is underway, and this effort includes sampling for PFAS in various samples from aquatic

and aquatic-dependent organisms.

The goal of any wildlife screening levels project would be to develop a methods document for terrestrial

risk assessment and derive toxicity values that apply in fish or wildlife tissues to more accurately

determine if internal burdens of toxic pollutants exceed concentrations that raise concern for that

organism’s health. These values would be screening levels to assess ecosystem health and guide clean-

up efforts, not regulatory values. For bioaccumulative pollutants, like PFOS, having tissue-based toxicity

values would be more accurate than translating a water or sediment concentration to an expected

internal concentration of concern. This project proposes to aggregate the available wildlife data

collected by MPCA, DNR, other state agencies, the EPA and agencies like Environment and Climate

Change Canada to develop wildlife ecologic risk screening values relevant to Minnesota wildlife.

Minnesota’s PFAS Blueprint • February 2021

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Work status: under consideration

Leaders: MPCA Environmental Analysis and Outcomes Division. Partners: DNR Wildlife Health;

MPCA Remediation Division.

Benefits: Developing wildlife screening values for PFAS will benefit wildlife management by

providing information about the impact that toxic pollutant stressors are having on a wildlife’s

health and population parameters. Because the DNR and other organizations are either actively

gathering PFAS wildlife data for other purposes or have already compiled relevant datasets, this

project provides added value to ongoing and completed data collection efforts.

Challenges: Though there are sufficient data to develop wildlife risk screening levels, especially after

DNR and MPCA Remediation complete sample collection of PFAS in various wildlife, additional data

will reduce uncertainties in the results.

Resources: This effort would require staff time to synthesize data, write a risk assessment

document, and review the resulting values.

Assess the need for acute wildlife risk assessment from exposure to PFAS-containing foam

Many PFAS are designed to be compounds that readily foam when agitated. Recent studies of what

appears to be naturally-occurring foams on surface waters have revealed to have concentrated PFAS,

sometimes at very high levels. In fact, PFOS concentrations in these foams have sometimes exceeded 20

ppm (or 20,000,000 ng PFOS per liter of foam). In contrast, site-specific WQC for PFOS concentrations in

surface water are 0.05 ng/L in water. Though this discovery of PFAS-enriched foam has led to the

realization that intentionally causing PFAS to foam in surface waters and collecting that foam may be an

effective and economical way to remediate PFAS, there are concerns about humans and wildlife being

exposed to this PFAS-enriched foam in uncontrolled settings. In past evaluations in 2007 of aquatic life

toxicity for site-specific WQC development of PFOS and PFOA (see above), MPCA developed acute

criteria to protect aquatic life. Recent monitoring of PFAS-containing foam found PFOS concentrations

greater than these acute toxicity criteria. The potential exposure of ecological species to PFAS from

foam or PFAS concentrating at the air-water interface is unclear, but may be more significant than

recreational exposure to people (where risk is expected to be low). This route of exposure may also be

contributing to the high levels of PFAS found in Michigan and Wisconsin deer harvested near

contaminated surface water sites. In this proposal, MPCA would evaluate information relevant to

determine if PFAS contaminated sites are contributing to acute toxicity in ecological species.

Work status: under consideration

Leader: MPCA’s Water Quality Standards Unit. Partners: MPCA Water Assessment Section, DNR

Wildlife Health, and the “Foamy Friends” subgroup of the Great Lakes PFAS Taskforce.

Benefits: Conducting this review would inform remediation actions associated with PFAS-containing

foams being observed on surface waters impacted by PFAS contamination and any future water

quality criteria or standards for protection of aquatic life.

Challenges: Conducting risk assessment for PFAS-containing foams on surface water is challenging

for several reasons. First, sampling of various surface water foams for PFAS has revealed that

concentrations of PFAS in foam can vary significantly across samples, even samples collected in the

same waterbody. It is also unknown how wildlife interacts with PFAS-containing foams – it is

possible that, like humans, wildlife tend to avoid the foam whenever possible. In addition, because

foams on surface water are ephemeral, it could be difficult to estimate how much exposure may be

occurring between wildlife and foams.

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Resources: This effort would require staff time from MPCA Water Quality Standards unit and

support from other MPCA and DNR partners. The effort would also likely be strengthened by

collaborating with the inter-state Great Lakes PFAS Taskforce subgroup called “Foamy Friends,”

which includes scientists from many partner states who are also investigating the topic of PFAS-

contaminated foam on surface waters.

Overview of intersectional issues

 Pollution prevention: Reducing PFAS pollution at the source places the cost burden of

treatment with the polluters. Conducting ecological risk assessment for all PFAS found in the

environment is not likely tenable. See the Preventing PFAS Pollution Issue Paper for actions

related to reducing the overall production and emission of PFAS products.

 Developing and expanding access to analytical methods: Analytical methods for PFAS are

expensive and time-intensive to run, and include only a subset of all PFAS that may be occurring

in surface water and biota – see the Measuring PFAS Effectively and Consistently Issue Paper for

more information on the costs and challenges associated with measuring PFAS in various

matrixes.

 Managing PFAS in waste streams: Landfill leachate, effluent and biosolids from wastewater

treatment plants, and contact water from composting facilities all contain PFAS stemming from

industrial and commercial uses of PFAS-containing products. Considerations will be needed to

ensure that waste facilities are not aggregating PFAS to an extent that harms ecological health.

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Remediating PFAS contaminated sites

Background

 There are several state and federal programs that work together to identify sites with contamination,

set remediation goals, and ensure that clean-up results in health-protective outcomes. These programs

include the federal Superfund program, the state Superfund program, and the state Brownfields

program.

 When it comes to PFAS investigation and remediation, federal regulation is lacking.

 There has been no action on the proposed EPA rule that would designate PFOA and PFOS as

“hazardous substances” under the federal Superfund law (CERCLA). Federal legislation designating

all PFAS as “hazardous substances” has not advanced.

 Though limited emission reporting requirements for PFAS went into effect for 2020 under the

federal TTRI program, several exemptions allow unreported PFAS emissions to continue.

 The DoD would likely not accept Minnesota’s health-based clean-up values for PFAS as

“applicable or relevant and appropriate requirements” (ARARs) at Department of Defense (DoD)

sites in Minnesota unless they are promulgated in state rule – most of Minnesota’s health-based

clean-up values would not be considered as ARARs by the DoD.

 Under MERLA, PFAS meets the definition of a hazardous substance based on its properties –

Minnesota currently has PFAS sites under investigation or in remediation and believes that there are

likely additional sites with PFAS contamination due to historic or ongoing uses of PFAS.

 Clean-ups are expensive and time consuming. Efforts that stem PFAS pollution at the source can be

expensive, but are essential for cost-effective management of PFAS in the environment.

What is Minnesota doing now?

 MPCA and MDH have established health-based clean-up values for several PFAS in multiple media.

 MDH developed values for five PFAS that are protective of human health through groundwater

exposure via drinking water.

 MPCA developed site-specific water quality criteria for PFOS protective of human health through

surface water exposure via consumption of freshwater fish.

 MPCA developed values for five PFAS that are protective of human health through soil exposure

via incidental soil ingestion.

 MPCA is remediating sites associated with 3M disposal of PFAS, including the widespread area of

surface water and groundwater contamination in East Metro.

 MPCA is investigating and remediating sites associated with PFAS releases from metal plating

industries and from uses of PFAS-containing firefighting foam.

 MPCA is collaborating with MDH on the Pilot PFAS Inventory Project.

 This initiative aims to leverage existing monitoring data for PFAS, data on types of industrial

activity occurring in Minnesota, and data on geologic susceptibility of aquifers to prioritize sites

for PFAS investigation.

Remediating PFAS contaminated sites

Summary

Minnesota’s PFAS Blueprint • February 2021

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What are remaining gaps and opportunities for action?

 Gap: PFAS are not listed directly as hazardous substances under either CERCLA or MERLA.

 Opportunity: Hazardous substance designation under CERCLA or MERLA would solidify existing

authorities regarding PFAS to require responsible parties to clean up PFAS contamination and

improve the state’s ability to recover costs from responsible parties when they fail to act.

 Gap: There is incomplete data listing which entities use or produce PFAS that could be released to the

environment.

 Opportunity: Authority to allow the state to request information on environmental contaminants

could help fill gaps in federal emission reporting requirements for PFAS.

 Opportunity: Continuing to expand the Pilot PFAS Inventory Project would help identify the

likelihood of finding PFAS contamination at existing sites and currently unknown sites.

 Gap: Though there are some existing health-based clean-up values for PFAS, additional guidance values

would help ensure protective clean-up goals and prioritize sites for investigation.

 Opportunity: MPCA could develop soil leaching to groundwater values and additional surface

water values for PFAS with health-based values available.

 Gap: Some industries, like car washes and metal platers, may have widespread historic and ongoing

uses of PFAS, and Minnesota may not have the resources to clean-up each impacted site.

 Opportunity: Minnesota could explore options for ways to supplement the Remediation Fund

should it be strained by an increase in PFAS sites without responsible parties.

How does this work benefit human health and the environment?

 Cleaning-up PFAS contaminated sites has the direct benefit of reducing PFAS concentrations in the

water, soil, and sediments to safe levels for humans and wildlife.

How does this work benefit Minnesota’s economy?

 Conducting site investigations to determine responsible parties for contamination places the cost

burden of PFAS controls with polluters rather than drinking water utilities and the general public, who

would otherwise fund drinking water treatment or other remedial actions.

 Remediation and redevelopment of contaminated properties encourages new businesses, creates jobs,

and results in an improved tax base.

 Drawing attention to the potential liabilities associated with PFAS release encourages responsible use

and management of PFAS, which decreases the likelihood of continued environmental contamination

and costly remediation efforts.

 Preventing adverse physical health outcomes associated with PFAS exposure and preventing negative

mental health outcomes associated with concern over exposure to these compounds is financially

beneficial for families and individuals.

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Background

Remediation is the process of cleaning up soil, water, sediment, and air after it has been contaminated

with pollutants, some of which may be hazardous substances. This work has two main goals: reducing

risks to human health and the environment, and ensuring properties are safe for reuse and

redevelopment. Site investigations and clean-up actions are often complex, involving multiple types of

contaminated media, receptors of concern, and potential routes of exposure. Identification,

investigation, and oversight of these sites is also complex; there can be involvement from federal

authorities, state authorities, those responsible for the contamination, and the impacted community.

Though there have been many success stories of redeveloping once-contaminated sites in Minnesota,

these projects often require large investments of money and time – the most strategic management of

environmental contaminants, including those in the PFAS family, is to prevent the need for remediation

actions in the first place.

MPCA first addressed PFAS contamination in 2002, when the Remediation Program traced PFAS to four

3M disposal sites in the East Metro. Over the past 18 years, investigations by MPCA and MDH into the

3M disposal sites have identified an area of groundwater contamination covering over 150 square miles

and impacting over 174,000 Minnesotans. Over this period, scientists discovered that PFAS

contamination is more widespread than originally believed, with many potential sources of PFAS

releases that are not tied to historic 3M disposal practices or chemical production companies. Currently,

MPCA is investigating a wide variety of sites with PFAS contamination and is collaborating with MDH’s

Drinking Water Protection program to identify potential PFAS sources to contaminated drinking water.

Remediation overview and regulatory authorities

The MPCA’s Remediation Division has authority to investigate and remediate sites to protect human

health, welfare, and the environment. This Division is broadly separated into the Brownfields Program,

which provides oversight to voluntary parties electing to address the investigation and clean-up of

contaminated properties, the Site Assessment and Site Remediation (Superfund) program, which

oversees the investigation and clean-up of sites of hazardous substances, or pollutants and

contaminants by responsible parties and at state-led sites, and the Petroleum Remediation program,

which oversees the investigation and clean-up of sites with petroleum releases by responsible parties

and at state-led sites.

Brownfields are abandoned, idled, or underused industrial and commercial properties where

redevelopment is complicated by actual or suspected environmental contamination. By overseeing

voluntary investigation and clean-up of brownfield sites, volunteer parties can proceed with

redeveloping contaminated properties in a safe manner that is protective to human health and the

environment. This benefits Minnesota communities by enhancing the livability of neighborhoods and

creating new businesses, jobs, and an improved tax base.

The CERCLA, commonly referred to as “Superfund,” is the federal law that governs how locations with

released hazardous substances are identified, prioritized, and ultimately cleaned up. The law includes a

list of substances that, if released, trigger legal responsibility and require the party responsible for that

release to investigate and, if necessary, remediate the release site. If there is no viable responsible

party, CERCLA provides authority for the EPA to conduct the investigation and remediation using funding

in the federal Superfund account. Under CERCLA, EPA produces the Superfund National Priorities List

Minnesota’s PFAS Blueprint • February 2021

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(NPL), which lists “sites of national priority among the known releases or threatened releases of

hazardous substances, pollutants, or contaminants.”

151

Similarly, MERLA, Minn.

Stat. ch. 115B,

establishes broad state

authority to respond to

releases or threatened

releases of hazardous

substances or pollutants and

contaminants. Minn. Stat.

§116.155 establishes a State

Remediation Fund from

which the MPCA and the

Minnesota Department of

Agriculture (MDA) can

spend money to investigate

and remediate releases or

threatened releases of

hazardous substances,

pollutants or contaminants,

and agricultural chemicals. The state lists its Superfund sites on the Minnesota Permanent List of

Priorities (PLP).

Whether a site is managed by the state under the MPCA Superfund program or by the EPA under the

federal Superfund program, properties will go through a series of steps that result in progressive risk

reduction (See Figure 6). Any direct exposure risks to human health are addressed as they are found and

do not need to wait until later stages in the process, which can take years to reach. Sites are first

assessed to determine the potential risks to human health or the environment and to identify the party

responsible for the release or threatened release. Once this initial site assessment is completed, a

detailed remedial investigation is taken to determine the scope of the pollution. The goal of this

remedial investigation is to answer questions like: In what media is the pollution found? How far has the

pollution spread? What are the relevant clean-up goals for the site? What are the options for responses

that could be taken to best fix this problem? After consideration of the potential response options

available, remedial action begins. This involves designing the clean-up process and taking the required

actions to reduce risks. Finally, the site enters the closing phases of the process, where administrative

steps are taken to finalize the project, prepare for long-term monitoring, and remove the site from the

priorities list. At this point, the property is ready for redevelopment or reuse. Altogether, this process

can take many years and require millions of dollars to complete.

Lack of federal regulations on PFAS

Although the regulatory structure for remediation is generally well-established, federal regulation

establishing liability for PFAS contaminated sites is not. Currently, federal law does not include PFAS as a

“hazardous substance” under CERCLA; EPA in 2019 proposed federal rulemaking to list two PFAS, PFOA

and PFOS, as CERCLA hazardous substances, but this rule has not been finalized.

152

Congress has

151

EPA. (n.d.) Superfund: National Priorities List (NPL). Retrieved from: https://www.epa.gov/superfund/superfund-national-

priorities-list-npl

152

Office of Information and Regulatory Affairs, Office of Management and Budget. (2019). Designating PFOA and PFOS as

CERCLA Hazardous Substances. https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201910&RIN=2050-AH09

Figure 6. Process of progressive risk reduction as sites move through the

Superfund process

Minnesota’s PFAS Blueprint • February 2021

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proposed including PFAS as hazardous substance, but these proposals have not become law.

153

Despite

the fact that no PFAS are currently listed as hazardous substances, EPA has tested for PFAS at the sites

on the National Priorities List “where there is a reason to believe PFAS might be present.”

154

Additionally, theDoD has acknowledged widespread contamination of groundwater near bases and

other facilities with historic use of PFAS-containing firefighting foam and Congress required DoD to

submit a remediation plan for cleanup of all water at or adjacent to a military installation that is

impacted with PFOA or PFOS.

155

At federally managed contaminated sites in Minnesota, the federal government is committed to clean

up to state and federal standards established by ARARs include cleanup standards and substantive

environmental protection requirements that are promulgated in rule under federal or state law.

Currently, the only federally-managed PFAS clean-up sites in Minnesota are managed by the DoD.

Because several of the health-based groundwater values (HBVs) derived by MDH for PFAS are not

promulgated in rule, EPA and DoD would not consider them to be ARARs and will not use them as clean-

up levels. However, EPA and DoD consider MDH’s Health Risk Limits (HRLs), which are promulgated in

rule, to be ARARs and would likely use them as clean-up values. (See the Quantifying PFAS Risks to

Human Health Issue Paper for more information about the guidance values derived by MPCA and MDH).

In all, the current status of the CERCLA hazardous substance definition not specifically including PFAS,

the lack of federally promulgated health-protective clean-up values, and the unwillingness of the DoD to

honor health-based guidance values derived in Minnesota as ARARs limit the effective remediation of

federal PFAS contaminated sites and federal response actions related to contaminated water supply

wells.

Federal regulation regarding mandatory reporting of PFAS use, discharge, and emissions is also lacking,

hindering the ability of cleanup programs to investigate potential releases of PFAS. The TRI program,

authorized under the Emergency Planning and Community Right to Know Act, requires entities to report

environmental releases of listed substances to air, water, or land. (The list of substances generated for

the TRI is different from, but generally inclusive of, hazardous substances listed under CERCLA.)

156

Until

2020, when Congress added an amendment to the National Defense Authorization Act that required

EPA to add some PFAS to the TRI list, there were no PFAS with reporting requirements. This meant that

Minnesota agencies had limited ability to determine which facilities were producing PFAS, importing

PFAS, or releasing PFAS to the environment. Though entities are currently tracking PFAS environmental

release data during 2020 (this data will be released by EPA in summer 2021), the new TRI reporting

requirements for PFAS include several exemptions. First, emission reporting will only be required for the

PFAS listed in the federal rulemaking, which does not constitute the full range of PFAS currently used in

industry and commerce. Second, reporting is only required if more than 100 pounds of PFAS-containing

products are released in a year and if that product, regardless of the quantity released, contains more

than 0.1% PFOA or greater than 1% other PFAS. Finally, some PFAS, like PFOS, have very low health-

based guidance values in drinking water. A facility releasing enough PFAS to cause exceedances in

health-based guidance values could still be below the mandatory reporting threshold.

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NYU School of Law. (2020, December 16). PFAS Federal Legislation. Retrieved from: https://www.law.nyu.edu/centers/state-

impact/press-publications/research/pfas-federal-legislation#

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US Senate Committee on Environment and Public Works. (2020). Carper, DPW Democrats As EPA to Share its Plan to Address

PFAS Contamination at Superfund Sites. Retrieved from: https://www.epw.senate.gov/public/index.cfm/2020/5/carper-epw-

democrats-ask-epa-to-share-its-plan-to-address-pfas-contamination-at-superfund-sites

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DoD. (2020). Department of Defense Remediation Plan for Cleanup of Water Impacted with Perfluorooctane Sulfonate or

Perfluorooctanoic Acid. Retrieved from: https://media.defense.gov/2020/Jul/10/2002451983/-1/-

1/1/DOD_REMEDIATION_PLAN_FOR_CLEANUP_OF_WATER_IMPACTED_WITH_PFOS_OR_PFO.PDF

156

EPA (2020) Consolidated List of Lists under EPCRA/CERCLA/CAA §112(r) (August 2020 Version).

https://www.epa.gov/epcra/consolidated-list-lists-under-epcracerclacaa-ss112r-august-2020-version

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Minnesota actions on PFAS investigation and clean-up

Minnesota has taken action to clean-up PFAS contamination under authorities provided by MERLA.

Minnesota’s investigation into PFAS contamination began in 2002, when PFAS contamination was traced

to four 3M disposal sites in the east metropolitan area of the Twin Cities. A consent order and a

settlement with 3M have resulted in funding for remediation of dump sites, development and

implementation of drinking water supply plans, natural resources preservation, and research into other

potential PFAS contamination not associated with 3M disposal sites. Over time, it has become clear that

widespread use of PFAS in many products, from firefighting foams to industrial mist suppressants, has

resulted in the potential for PFAS contamination to be far more widespread than originally believed.

Currently, MPCA is investigating a wide variety of sites with PFAS contamination and is collaborating

with MDH’s Drinking Water Protection program to identify additional potential PFAS sources of

contaminated drinking water.

Establishing health-protective clean-up goals

Many PFAS cause adverse health effects in humans and wildlife when exposure exceeds toxic

thresholds. Currently, Minnesota established health-based drinking water guidance values for five PFAS,

incidental ingestion guidance values for the same five PFAS, and site-specific WQC for one of those PFAS

(PFOS). However, Minnesota has not developed soil leaching values that would protect against PFAS

leaching to groundwater, air values, or sediment quality target values. There are currently no federal or

state drinking water standards (MCLs) for PFAS.

The lack of publicly available toxicity data for most PFAS hampers the development of health-based

guidance (see the Quantifying PFAS Risks to Human Health Issue Paper). Similarly, there are limited data

available for most PFAS to calculate risk-based values protective of aquatic life and other wildlife (see

the Protecting Ecosystem Health Issue paper).

Challenges in PFAS site remediation

There are several technical challenges associated with remediation of PFAS-contaminated sites. First, it

can be challenging to identify which PFAS are present when many novel PFAS do not have analytical

methods or standards available. Non-targeted approaches to identifying PFAS are available, but access

to the required laboratory equipment and staff expertise are limited. Using only standard analytical

methods does not detect if new or less-commonly studied PFAS were present at the site (see the

Measuring PFAS Effectively and Consistently Issue Paper). Once PFAS are identified, risk-based guidance

values are needed to set clean-up goals. MPCA and MDH may need to develop new clean-up goals if

existing values are not available. Then, the MPCA needs to determine an appropriate course of action to

reduce concentrations below those risk-based thresholds. For many PFAS, these risk-based values for

protecting human health or ecological health are currently unavailable. Finally, there are limited options

available for treating PFAS contaminated media and disposing of or destroying PFAS waste generated as

part of remediation, and these options are often quite expensive (see the Managing PFAS in Waste Issue

Paper). Significant work is needed to fill these gaps. Overall, clean-ups for PFAS-contaminated sites are

expensive and time consuming. Therefore, preventing PFAS contamination should be a high priority.

Past and ongoing efforts

The following sections describe completed and ongoing work related to identifying and

remediating sites with PFAS contamination. While every contaminated site is unique, the projects

described below give a sense of where PFAS contamination may be found and what remedial actions

would be needed to clean it up. Several projects are related to the investigation and remediation of

historic 3M disposal sites for PFAS waste. Other projects address remediation of PFAS contamination

stemming from industries or activities outside of PFAS manufacturing, such as emissions from PFAS

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products used in metal plating and use of PFAS-containing firefighting foam. Challenges that arise in

undertaking remediation projects include establishing clean-up values for relevant media, determining

the extent PFAS disperses in the environment, and evaluating how to safely manage and dispose of

contaminated materials. In addition to work related to known PFAS sites, MPCA is actively identifying

new sites that, due to historic industrial activity, are likely to contain PFAS contamination. This initiative

is currently in the pilot phase.

Activities related to PFAS investigation and remediation at 3M PFAS-contaminated sites

Implementation of the 2007 Consent Order

In May 2007, 3M and the MPCA entered into a Settlement Agreement and Consent Order (2007 Consent

Order), which outlined requirements for 3M to address PFAS releases from three 3M disposal sites in

Washington County: the Oakdale Site,

157

the Woodbury Site,

158

and the Cottage Grove Site.

159

The 2007

Consent Order required 3M to complete investigations at each site to determine the extent and

magnitude of PFAS contamination and to undertake the appropriate remedial actions to address

releases. To meet the terms of the 2007 Consent Order, 3M proposed the excavation and removal of

PFAS impacted soil and sediment, installation of an enhanced groundwater control and treatment

system, and long-term groundwater and surface water monitoring at each site, as appropriate. 3M is

also required to file Environmental Covenants (which place restrictions on future land uses) for each site

with the appropriate County Office. The 2007 Consent Order additionally required that 3M provide

alternative drinking water sources to those public and private drinking water supplies with levels of PFAS

contamination above MDH drinking water criteria. MPCA requested that 3M conduct additional

evaluation of the surface water controls at the Oakdale site including additional surface water,

sediment, and ground water sampling to help determine if more surface water remedies to control PFAS

releases through Raleigh Creek are needed. 3M completed the additional work in fall of 2020. The MPCA

and MDH continue to monitor both public and private drinking water supplies in the East Metro to

ensure compliance with the 2007 Consent Order.

Work status: ongoing

Leader: MPCA East Metro Unit, MPCA Remediation Division. Partners: MDH Site Assessment and

Consultation, MPCA Legal Services Unit, MPCA contractors.

Benefits: The 2007 Consent Order prevented further PFAS contamination from the subject disposal

sites, and provided funding for interventions to reduce PFAS in impacted drinking water systems.

Biomonitoring of individuals exposed to 3M contaminated drinking water showed significantly

reduced levels of PFAS in blood serum after implementation of the drinking water intervention (See

the Limiting PFAS Exposure from Drinking Water Issue Paper).

Challenges: Geologic conditions in the region surrounding the Oakdale disposal site and Washington

County Landfill resulted in PFAS contamination spreading through interconnected surface water and

groundwater systems. A series of pipes and man-made water conveyances (called the Project 1007

Corridor) designed to more efficiently drain water from the region to the St. Croix River contributed

to the surface water transport of PFAS. There continues to be significant levels of PFAS in surface

water and groundwater in the region. Remedial investigations of the Project 1007 Corridor

are currently underway.

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MPCA (2008). 3M Oakdale Disposal Site Proposed cleanup plan for PFCs. [fact sheet]. Retrieved from:

https://www.pca.state.mn.us/sites/default/files/Fc-s3-06.pdf

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MPCA. (2008). 3M Woodbury Disposal Site Proposed cleanup plan for PFCs. [fact sheet]. Retrieved from:

https://www.pca.state.mn.us/sites/default/files/c-pfc3-02.pdf

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MPCA. (2009). 3M Cottage Grove Site Proposed cleanup plan for PFCs. [fact sheet]. Retrieved from:

https://www.pca.state.mn.us/sites/default/files/pfc3-04.pdf

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Resources required: Oversite of 3M activities involved many staff at MPCA and MDH, including risk

assessors, hydrologists, engineers, legal staff, and others. Monitoring at these sites is ongoing.

Washington County Landfill triple liner installation (2009-2011)

The Washington County Landfill was used by 3M for disposal of PFAS containing wastes generated at the

3M Cottage Grove facility. This landfill falls under the authority of the MPCA’s Closed Landfill Program

(CLP), which means that Minnesota is financially responsible for long-term obligations related to

releases of hazardous substances from the landfill. MPCA, under direction from the Legislature,

determined that the most appropriate action to address the PFAS contamination at the site was to

consolidate the waste material at the landfill onto a triple-liner system. Under the terms of the 2007

Consent Order, 3M contributed $8 million towards the implementation of the triple-liner system at the

landfill. 3M also entered into an agreement with the City of Lake Elmo to pay for the connection of

approximately 200 homes near the landfill to the city’s public water supply system. Overall, 1.89 million

cubic yards of waste were moved in order to add a lining to the landfill. The MPCA continues to monitor

private drinking water wells that were not connected to the city drinking water system.

Work status: completed

Leaders: MPCA Closed Landfill Program. Partners: MPCA East Metro Unit.

Benefits: The lining of the Washington County Landfill significantly reduced the discharge of PFAS

from this site. Continuous monitoring of wells surrounding the landfill ensures that drinking water

wells will be protected into the future.

Challenges: This project faced several logistical challenges. The entire landfill needed to be dug out

in order to install liners, so the materials were temporarily moved to the surface. This resulted in

concerns from the community over the exposed waste being in contact with rainwater and

generating leachate. Although there was a desire to build a leachate recirculation system within the

landfill to reduce the overall volume of waste and leachate, compaction of materials in the landfill

made this not possible.

Resources: This project was extensive and took over two years to complete. 3M contributed $8

million to the project, but the total cost was approximately $24 million.

Remediating the Project 1007 Corridor

The Project 1007 Corridor is a system of storm water pipes, open channels, catch basins, and dams

constructed in 1987 that direct the flow of water from the Tri-Lakes area (lakes Jane, Olson, and

DeMontreville) to the St. Croix River in an effort to reduce flooding. The engineered systems capitalized

on existing creeks and lakes to facilitate the desired flow path – one of those creeks, Raleigh Creek, also

flows through the former 3M Oakdale disposal site where PFAS discharged into the creek (and continues

to do so). Additionally, from the late 1980s to the early 1990s, untreated water from the Washington

County Landfill was discharged into the Project 1007 Corridor. Crucially, these additions of PFAS to the

man-made drainage system allowed PFAS to spread past the natural hydrological basin where they were

discharged and PFAS moved into the St. Croix drainage basin. The karstic geology in this watershed has

also allowed for PFAS to flow from groundwater to surface water and back to groundwater in complex

patterns. Figure 7 illustrates the geographic extent of hydrologic systems influenced by Project 1007.

Minnesota’s PFAS Blueprint • February 2021

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Figure 7. Map of Project 1007 Corridor.

The 2018 3M Natural

Resources Settlement

(2018 Settlement) with

MPCA states that “the

MPCA shall conduct a

source assessment and

feasibility study regarding

the role of the Valley

Branch Water District's

project known as Project

1007 in the conveyance of

Perfluorochemical (PFCs)

in the environment.” The

goal of the assessment is

to understand how

Project 1007 is

contributing to PFAS

contamination in the East

Metro Area. The data

collected during this

assessment is being used

to conduct feasibility

studies for potential

mitigation efforts.

Work status: ongoing

Leader: MPCA East Metro Unit, Remediation Division. Partner: State contractors, MDH Site

Assessment and Consultation, Valley Branch Watershed District, MnDOT.

Benefits: Human and ecological receptors will benefit from removal of PFAS from multiple media

(sediment, surface water, groundwater) in this region. Positive health outcomes are anticipated for

human and ecological receptors from improved water quality and the associated reduction of

bioaccumulation of PFAS through the food chain. A long-term approach to gradient control and

treatment of the regional subsurface PFAS plumes will result in improved groundwater quality. A

similar set of benefits will be realized for impacted surface water that is hydrologically connected to

the regional drinking water resources.

Challenges: There are many technical challenges that will need to be overcome to successfully

remediate PFAS plumes impacting the groundwater and surface water in this region. PFAS-impacted

surface water and sediments pose challenges. Considerations are underway regarding disposal of

impacted sediments, potential surface water treatment systems, and the amount of time treatment

systems would need to be operational to address the contamination. Treatment, disposal, and

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destruction technologies for PFAS are evolving quickly. In many ways, the scale of PFAS remediation

in this project is unprecedented – Minnesota is learning and evolving to new information as the

project proceeds.

Resources: Significant resources from the 2018 Settlement funding are necessary to continue

investigation and remediation of this region. This project has involved partnerships from many

experts across Minnesota agencies, including various media specialists, hydrologists, geologists,

engineers, risk assessors and toxicologists. The project has contractor support to lead well-drilling,

sample collection, risk assessment, and many other elements of the project. External stakeholder

groups have also supported the project by participating in the development of regional, long-term

remedial options for groundwater resources. Through fiscal year 2021, over $4 million will have

been spent on this effort.

Activities related to PFAS use in other industries

Remediating metal plating sites

Following the initial discovery of elevated PFOS concentrations in Bde Maka Ska, a Minneapolis lake,

MPCA conducted extensive stormwater monitoring to find the PFOS source. This monitoring revealed

that PFOS was released to air by a metal plating-on-plastic facility. Some of the emitted PFOS landed on

the roof of the facility, where it traveled via stormwater to a wetland and lake a mile away. In the lake,

MPCA found that the PFOS built up in fish tissue to levels of concern for human consumption, leading to

development and application of a site-specific water quality criteria, fish consumption advice from MDH,

and the waterbody being included on the Impaired Waters List. This discovery sparked general concern

over PFAS emissions from metal plating facilitates, especially facilities that plate metal onto plastic,

where PFOS-containing mist suppressant and wetting agent products are often used.

Since the discovery of metal platers as potential point sources of PFAS, especially PFOS, MPCA’s

Remediation and Compliance and Enforcement programs have engaged in actions to reduce PFOS

emissions from some of these metal plating facilities and clean-up the resulting contamination in

drinking water, surface water, and fish. For example, a metal plating facility in Brainerd was discovered

as a source of PFAS to the city’s wastewater treatment plant, and voluntary actions were taken to end

the use of PFOS products in the plant and to further manage the PFOS released.

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Enforcement and

remediation activities related to several of these metal plating facilities are ongoing.

Work status: ongoing

Leaders: MPCA Remediation, Environmental Analysis and Outcomes, and Industrial Divisions.

Partner: DNR

Benefits: Minnesota was at the forefront of discovering that chrome plating facilities potentially act

as major source of PFOS to surface water, drinking water, wastewater effluent, and biosolids. The

research and communication around the initial plating facility investigation has led to many states

and federal agencies being involved in researching and reducing PFOS emissions from plating. Many

plating facilities switched to non-PFOS containing mist suppressants shortly after the discovery that

PFOS-based mist suppressants were the source of elevated PFOS concentrations in some surface

water, wastewater, effluent, and biosolids. However, it is not clear that the replacement mist

suppressant and wetting agent products are fully PFAS-free.

Eliminating the use of PFOS-based mist suppressants and wetting agents at chrome plating facilities

significantly reduced PFOS concentrations in wastewater and stormwater, which led to reductions in

surface water and fish tissue concentrations at impacted waterbodies. The improvement in water

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MDH (2008). Health Consultation, PFOS detections in the city of Brainerd, Minnesota. Retrieved from:

https://www.health.state.mn.us/communities/environment/hazardous/docs/pfas/pfosdetectbrainerd.pdf

Minnesota’s PFAS Blueprint • February 2021

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quality from actions at metal plating sites is directly benefiting Minnesotans who eat fish from those

waterbodies, some of whom rely on fishing as a healthy protein source, by reducing their exposure

to PFOS. Remediation activities at these sites also ensures that drinking water sources potentially

impacted by these sites are tested, and treatment is provided as needed. Ecological receptors also

benefit from reduced exposure to PFOS and other PFAS in surface water surrounding metal plating

facilities.

Challenges: Though extensive remediation and mitigation at one facility did reduce the

concentration of PFOS leaving the facility in wastewater and stormwater, the residual amounts of

PFOS in this facility continue to be a meaningful source of PFOS to the environment. It is not clear

how to go about removing the PFOS residuals, and collaboration among Minnesota, other states,

and EPA on this topic is ongoing.

Anticipated resource needs: Remediation sites associated with metal plating may be active for years

and require a number of staff from different programs to manage. For example, one such site has

been active for thirteen years and will likely need staff time and monitoring funds for years to come.

Statewide survey of PFAS-containing firefighting foam usage

PFAS, including PFOA and PFOS, used in firefighting foam products are especially effective in extinguishing

liquid fires, such as fires of fuel, solvents, or other chemicals. For this reason, federal regulations require

firefighting products containing foam (aqueous film-forming foam, or AFFF) to be present at petroleum

refineries, all FAA regulated airports, and other facilities. From 2008-2011, MPCA reviewed and evaluated

every fire department and agency in Minnesota to determine which may have used firefighting foam

containing PFAS. This effort was funded by 3M under the terms of the 2007 Consent Order, which required

that 3M provide $5 million to the MPCA for research activities that would help determine the extent of

PFAS contamination in Minnesota outside of the 3M PFAS disposal sites.

Firefighting training sites and fire sites where PFAS-containing Class B firefighting foam is or was used

were ranked for their potential to release PFAS to the environment. The ranking included a number of

criteria such as the types and amounts of foam used, the frequency of the training events, the

environmental setting, and nearby receptors. MPCA and MDH then followed-up by conducting soil,

groundwater, and public drinking water system sampling at high priority locations with reported PFAS-

containing foam. Data collected at these sites were documented in several reports.

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Site-specific

investigations identified PFAS in soil, groundwater, surface water, or sediment at many of the high

priority sites. PFAS were found in surface water or groundwater at concentrations above HRLs for

drinking water at the following sites:

 Former firefighting training area behind the Richfield Ice Arena, Richfield

 Former firefighting training areas at Minneapolis-St. Paul International (MSP) Airport

 Firefighting training area at the Marathon Refinery, St. Paul Park

 Apple Valley-Burnsville-Lakeville-Eagan (ABLE) Training Center in Burnsville

 Firefighting training area at the Bemidji Regional Airport

 Firefighting training area at the Lake Superior College Emergency Response Training Center

(ERTC), Duluth

 Former firefighting training area at the Duluth International Airport

 Western Area Fire Training Academy (WAFTA) in St. Bonifacius

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MPCA. (2010). Perfluorocarbon (PFC)-Containing Firefighting Foams and their use in Minnesota. Retrieved from:

https://www.pca.state.mn.us/sites/default/files/c-pfc1-19.pdf

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MPCA (2010). Report of Investigation Activities at select Firefighting Foam Training Areas and Foam Discharge

Sites in Minnesota. Retrieved from: https://www.pca.state.mn.us/sites/default/files/c-pfc1-09.pdf

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In response to groundwater exceedances of HRLs, MDH began in 2011 to identify and sample water

supply wells potentially at risk. Sampling water supply wells near several AFFF use sites has continued to

the present and has been re-initiated near several sites as PFAS drinking water HRLs have continued to

decrease and method detection levels have improved. Response actions to replace supply or treat water

with PFAS concentrations above current drinking water advisory levels have been implemented at

several sites, including two private wells near the Duluth Air Force base and municipal wells near the

Bemidji airport.

Work status: completed

Leaders: MPCA Remediation Division and MDH Site Assessment and Consultation. Partners:

Participating firefighting departments and agencies, the State Fire Marshal’s office.

Benefits: The firefighting foam survey effort led to the identification of several PFAS-impacted sites

that continue to be actively monitored by MPCA and MDH. Actions were taken at drinking water

wells that had exceedances of HRLs to reduce exposure. Additionally, the survey led to collaboration

between MPCA, MDH, and the State Fire Marshal’s office, which led to local fire departments having

greater awareness of the health and environmental risks of PFAS. Minnesota recently passed a law

banning PFAS-containing firefighting foams for training and testing purposes under most

circumstances, but this early outreach to fire departments led to a reduction in PFAS-containing

firefighting foam use in training before that ban went into effect, reducing the amount of PFAS

released into the environment.

Challenges: Early monitoring for PFAS was difficult due to high detection limits, a limited number of

PFAS analytes, and a lack of health-based guidance values that could be used for comparison. Since

beginning this effort in 2008, MDH has developed health-based guidance for five PFAS and analytical

methods have improved.

Resources required: This work involved several staff overseeing outreach to firefighting facilities,

sampling of various media at high-priority sites, and interventions at private drinking water wells

with exceedances of HRLs. This work was funded by money from the 3M settlement.

Remediating sites impacted by PFAS-containing firefighting foam

MPCA is currently overseeing several site investigations and remedial actions at sites that have been

impacted by PFAS-containing firefighting foam usage. Some of these sites are associated with DoD

activities. The National Guard Bureau, on behalf of the Minnesota Air and Army National Guard and the

US Air Force, began conducting preliminary assessments and site inspection investigations at active

operational areas where PFAS-containing firefighting foams have been used or stored. These

investigations were completed for the Minnesota Army National Guard installations at Camp Ripley and

St. Cloud, for the Minnesota Air National Guard 148

Fighter Wing installation at the Defense Logistics

Agency, and for the US Air Force and the Minnesota Air National Guard 133

Airlift Wing installations at

the MSP Airport. The initial investigations at these sites revealed that potentially significant releases of

PFAS and PFAS-containing firefighting foam have occurred at each of these facilities. The respective

military components are in the process of evaluating the risk and priority for funding remedial

investigation and response actions at these sites in Minnesota given the hundreds of other military

installations around the US also in need of remediation. Currently, MPCA is investigating potential

impacts to groundwater, drinking water, surface water, and biota in the areas around these sites as

funding allows.

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Work status: ongoing

Leader: MPCA Remediation Division. Partners: Responsible military departments in the DoD.

Benefits: PFAS-containing firefighting foams have proven to be a major source of PFAS to the

environment. Cleaning up these sites will reduce risks to human health and the environment.

Requiring that the DoD pay for remediation at sites where the agency released PFAS-containing

foams will reduce cost burdens on municipalities and individuals with impacted drinking water.

Challenges: Given the magnitude of PFAS pollution caused by DoD activities in the US (which is

estimated to produce potential cleanup liabilities that exceed $2 billion), DoD sites in Minnesota are

on a long queue of sites requiring clean-up action. Additionally, given that there are currently no

federal standards for PFAS (no MCLs or hazardous substance designation under CERCLA), it is not

fully clear which requirements DoD is subject to for clean-up. The federal government is unlikely to

accept Minnesota’s HBVs as ARARs for any contaminants, but would accept HRLs, which are

promulgated by MDH.

Resources: Investigating and managing sites impacted by PFAS-containing foam has required

multiple staff and many years of effort. Continued investigation and oversite of DoD activities will

require additional staff time and funding for the foreseeable future.

Deriving health-based clean-up levels

Established and updated site-specific PFOS criteria to support clean-ups

Water Quality Criteria (WQC) are site-specific surface water values that are applied to address pollution

in areas of known surface water contamination. These WQC are different than WQS in that they do not

apply to the entire state, only to waterbodies explicitly included in the criteria. WQC are developed

based on methods and authorities in state statute and the federal CWA (See Minn. R. ch. 7050). The

MPCA Remediation Program is managing sites with PFAS surface water contamination and requested

WQCs for PFAS be derived for impacted waters to inform clean-up efforts.

In October 2020, MPCA released a new PFOS WQC that applied to targeted waterbodies including Lake

Elmo and connected waterbodies in the Project 1007 corridor in Washington County. When deriving

WQC for those sites, MPCA also took the opportunity to update existing WQC for PFOS elsewhere in the

State (Bde Maka Ska, and Pool 2 of the Mississippi River). MPCA prioritized deriving a PFOS WQC

because PFOS has the highest bioaccumulation potential in fish compared to the other PFAS with health-

based guidance values available. This high propensity of PFOS to accumulate in fish means that the

largest pathway of exposure for those interacting with PFOS-contaminated water could be through

consuming fish caught in that waterbody. MPCA is in the process of developing WQC for other PFAS

found in surface waters in these impacted waterbodies.

PFOS is known to accumulate to levels of concern in fish and is transferred to humans when consumed,

potentially causing adverse health effects. The site-specific WQC for PFOS in fish tissue and water

incorporate a toxicological and exposure approach that is similar to that used by the MDH to develop

drinking water values. This approach protects the most vulnerable populations to PFOS toxicity, which

are developing fetuses and newborn infants being exposed to PFOS through the placenta during

pregnancy and through breastmilk in early life. In developing this new WQC for PFOS, MPCA reviewed

new fish consumption survey datasets from the MDH, Great Lakes Consortium for Fish Consumption

Advisories, and other regional and national studies relevant to the amount and types of freshwater-

caught fish consumed by women of childbearing age (ages 15 to 50). Because PFOS and other PFAS are

developmental toxicants, characterizing potential exposure to this subgroup of fish consumers from

PFOS is very important. The interim fish consumption rate for women of childbearing age used in this

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PFOS WQC is over twice the default rate for adults who eat freshwater-caught fish and is based on a

study lead by MDH called, Fish are Important for Superior Health (FISH).

The new WQC for PFOS can be expressed either as a fish tissue concentration or as a water

concentration. For fish tissue, the WQC is 0.37 nanograms PFOS per gram (ng/g). The corresponding

WQC for water is 0.05 nanograms per liter (ng/L). The goal of these WQC is to reduce the levels of PFOS

in water, which should eliminate the need for additional protections like fish consumption advisories.

Work status: ongoing

Leader: MPCA Water Quality Standards Unit. Partners: MPCA Water Assessment and MDH Health

Environmental Surveillance and Assessment.

Benefits: PFOS WQC are based on protecting people’s health from the presence of this toxic

pollutant in Minnesota’s surface waters and fish. The criteria provide numeric targets for MPCA

programs to use in remediation cleanup, wastewater permitting, and other environmental

protection authorities. Reductions of PFOS in fish tissue have already been documented in some

surface waters due to national restrictions of some PFAS, including PFOS, and ongoing remediation

activities. Any efforts to reduce PFOS pollution also benefit wildlife.

Challenges: The PFOS WQC consist of an applicable fish-tissue concentration and surface water

concentration. These values are very low and require the use of the most recently developed

analytical methods to assess. The fish-tissue WQC of 0.37 ng/g can be accurately quantified by

MPCA contract labs, but the water concentration of 0.05 ng/L cannot. The MPCA’s Effluent Limit

Unit is working with the Environmental Data Quality Unit to develop guidance related to these

analytical issues.

Resources: The development of the PFOS WQC took an MCPA staff person approximately one year

and involved the support of several other technical staff at MPCA and MDH. This effort was possible

because MDH had already conducted a human health assessment for PFOS, containing toxicity

values and a serum model for understanding PFOS transfer to infants. Currently, the Water Quality

Standards Unit is developing new site-specific WQC for PFOA (which would allow for additional

updates to existing WQC for Bde Maka Ska and Pool 2), PFBA, PFHxS, and PFBS – primarily based on

the potential for recreational risk. These PFAS also have MDH toxicological values and health-based

guidance for drinking water that are relevant for this work. This work is anticipated for completion

in 2021.

Derived PFAS soil ingestion values to support clean-ups

Children are especially likely to have exposure to contaminants in soil, and studies have quantified the

amount of soil children incidentally ingest while playing outdoors. However, adults can also be exposed

to contaminants in soil. Site-specific soil screening values protective of human health for both residential

exposure (focused on protecting children’s soil exposure) and industrial or commercial exposure

(focused on adult soil exposure) were derived to support remediation activities in the East Metro.

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These values are also relevant to sites with soil PFAS contamination in Minnesota. SRVs are used to

determine potential public health risks resulting from direct exposure to impacted soil, but are not used

as clean-up values. The SRVs for PFAS were last revised in November 2019.

Work status: completed, with additional future work possible

Leaders: MPCA Environmental Analysis and Outcomes Division.

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MPCA. (2017). Revised per- and polyfluoroalkyl substances human health soil reference values.

https://www.pca.state.mn.us/waste/what-minnesota-doing-about-pfas

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Benefits: Guidance values for soil ingestion are used to determine if there are potential public

health risks posed by soil exposure in various settings.

Challenges: Soil guidance values for additional PFAS would be helpful, but toxicological assessments

are needed before such values could be derived. The lack of oral toxicity data has so far prevented

risk assessments for several of the long-chain PFAS that are most likely to remain sorbed to soils or

sediments. Additionally, risk-based values derived to protect against leaching of PFAS from soils to

groundwater may need to be more stringent than values protecting against incidental ingestion of

soil.

Resources required: This effort to derive soil risk values involved a small team of human health risk

assessors in the MPCA, with support from toxicologists in the environmental health team at MDH.

The MPCA has lost human health risk assessment expertise in 2020 and is working to fill a position

to help support this work. Additional effort will be required to update soil risk values as the

underlying toxicity information for PFAS is updated.

Identifying new PFAS sites

Continue developing the Pilot PFAS Inventory

The goal of the Pilot PFAS Inventory is to develop a comprehensive database of known and potential

PFAS-contaminated sites and tools to prioritize investigations into those sites. In 2017, a multi-phase

protocol was developed to identify and prioritize locations where PFAS may be present. The protocol

maps potential PFAS-generating businesses and receptors, such as drinking water sources, to determine

potential risk to human health and the environment. A four-county pilot study (including Dakota,

Olmsted, St. Louis, and Stearns counties) was launched to validate the protocol by testing for PFAS in

groundwater, surface water, air, soil, and sediment at high priority sites. MPCA is partnering with MDH

to incorporate results of ongoing drinking water monitoring into the site prioritization tools.

Work Status: ongoing

Leader: MPCA Remediation Division. Partner: MDH Drinking Water Protection.

Benefits: PFAS data is collected over many programs in multiple agencies, making it difficult to

synthesize information, analyze trends, and prioritize future actions. The PFAS Inventory is compiling

information about industrial activities that may have resulted in PFAS releases and PFAS data from

multiple monitoring programs in a format that can be easily mapped and analyzed, facilitating more

timely investigations into sites with the highest likelihood of impacting human health and the

environment. The prioritization tools developed as part of the Pilot PFAS Inventory will be validated

by conducting site investigations for PFAS in multiple media at high-priority sites.

Challenges: The assessment of PFAS contamination requires data on the presence of current and

historic potential PFAS-generating businesses. To identify sites with industrial activities that may

have resulted in PFAS releases, industry codes associated with PFAS use were collected from the

National American Industrial Classification System. However, not all businesses in industries

identified as having potential PFAS use will actually have had PFAS on site. For example, airports are

listed as a potential major source of PFAS release, but small airstrips at farms, for example, are

unlikely to have firefighting foam usage that resulted in PFAS release. Data about facilities

associated with current industries types were collected using the Made in Minnesota database,

which is hosted by the Minnesota Department of Employment and Economic Development.

However, a facility’s inclusion in the Made in Minnesota database is voluntary and the database is

therefore not comprehensive. Data on historic businesses that may have potentially generated or

used PFAS were collected from the state’s PLP, which includes Superfund sites in Minnesota.

Together these databases provide some information on facilities that have past or present potential

PFAS uses, but do not capture all potential facilities with PFAS uses and environmental releases in

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the state. The inclusion of some PFAS in the TRI starting in calendar year 2020 will provide more

detailed data on current PFAS emissions, but there are limitations in the reporting requirements

that will allow some PFAS releases to go unreported.

Resources: This project is currently in a pilot stage that includes gathering data and prioritizing sites

in four counties. The cumulative costs for the development of the protocol, identification of priority

sites, evaluation of data, and launch of the pilot study is approximately $125k for years 2016-2021.

This includes funding made available through an EPA MPG. The methods developed in this project,

after their verification, could be applied in multiple areas.

Gaps and opportunities

There are several opportunities that could help fill ongoing gaps in areas related to remediation of PFAS-

containing sites. These opportunities include refining legal authorities related to PFAS investigation and

clean-ups, developing additional guidance for PFAS site remediation, and exploring options for ways to

supplement the state Remediation Fund should it be strained by an increase in PFAS sites without

responsible parties.

There are several areas where additional legislative action would enhance the agency’s ability to

respond to PFAS pollution. Despite prior legal and regulatory actions in Minnesota, there remain

challenges to state authorities to regulate PFAS. Legislative changes to the hazardous substance

designation under MERLA would solidify existing authorities regarding PFAS in Minnesota. Similarly,

congressional changes to the designation of PFAS under CERCLA would clarify federal authorities.

Additionally, there is a lack of data identifying which entities use or produce PFAS that could be released

to the environment. Using the Pilot PFAS Inventory to identify unknown sites could be a step to fill this

data gap; however, this effort is restricted by limitations in publicly available information about PFAS

use and release. Additional statutory authority that would allow MPCA to request information on

environmental contaminants could also fill gaps in the available information. This would benefit the

many initiatives where additional information held by private parties would inform risk assessment or

site investigation.

In addition to gaps related to environmental release of PFAS, there are also gaps in guidance related to

determining risk-based clean-up values and monitoring needed to prioritize sites. Though there are

some existing clean-up values for PFAS, additional guidance values would help ensure protective clean-

ups and prioritize sites for investigation. MPCA could develop soil leaching to groundwater

values and additional surface water values using the existing health-based values from MDH for five

PFAS. Additional risk assessments for PFAS from MDH would allow for corresponding surface water and

soil values to be derived. Finally, there is a gap in guidance for when investigations of sites should

include monitoring for PFAS. Filling these gaps would ensure that clean-ups are health-protective and

that actions at sites are consistent.

There is work underway to remediate many PFAS-containing sites in Minnesota, but there are likely

many more businesses and industries with PFAS releases than could be addressed in the remediation

program. Some common industries, like car washes or metal platers, may have widespread historic and

ongoing uses of PFAS, and the state may not have the resources to clean-up each impacted site in the

near-term should the responsible party be unable to do so. Minnesota could consider options for ways

to supplement the state Remediation Fund should an increase in PFAS remediation sites without

responsible parties strain that fund. The following sections describe these possible opportunities to fill

existing gaps in more detail.

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Request additional legal authorities associated with PFAS Remediation

Formally define PFAS as a hazardous substance under MERLA

The Legislature should specifically include PFAS in its definition of hazardous substances under the

Minnesota Environmental Response and Liability Act, or MERLA. Under MERLA, compounds are

considered hazardous substances if they meet one of several criteria, including if they are a hazardous

waste. Hazardous waste is defined as any hazardous waste in Minn. Stat. 116.06, subd. 11, any

substance identified as a hazardous waste under rules adopted by the agency, and any hazardous waste

as defined in the Resource Conservation and Recovery Act (RCRA), which is listed or has certain

identified characteristics. PFAS are currently considered hazardous substances based on their properties

as hazardous waste under Minn. Stat. 116.06, subd. 11; but, specifically designating PFAS as a hazardous

substance in statute would clarify MPCA’s authority to respond to releases of PFAS under MERLA. It

would reduce legal challenges over whether PFAS is a hazardous substance or not. Including PFAS in the

definition of hazardous substances would also provide greater clarity for the state to require responsible

parties to investigate or clean-up releases under Minn. Stat. 115B.17 and recover costs from responsible

parties that fail to take all appropriate and necessary actions to investigate or clean-up releases of PFAS

as provided in Minn. Stat. 115B.04.

Work status: requires legislative action

Leaders: MPCA Remediation Division.

Benefits: There are several benefits to proposing that the Legislature amend MERLA to specifically

include PFAS in its definition of hazardous substances. Legal challenges can delay the agency’s ability

to quickly respond to PFAS related releases, including those in environmental justice

areas. Additionally, if the Legislature were to amend MERLA’s definition of hazardous substances to

specifically include PFAS, it would expedite MPCA’s actions to require responsible parties to take

remedial actions or recover costs from responsible parties that are reluctant to investigate or clean-

up PFAS contamination that may be threatening human or ecological health. Finally, specifically

identifying PFAS in the definition of a hazardous substance would alert PFAS users of the hazardous

nature of the chemical and encourage entities that use or produce PFAS to invest in safer alternative

chemistries.

Challenges: The family of PFAS is large and diverse, with different PFAS causing different problems

in human biological functioning, wildlife biological functioning, and overall ecological health. The

persistence of PFAS as a class combined with the known toxic effects of many individual PFAS is

sufficiently troubling to warrant designating the entire class as hazardous substances. If a chemical is

highly persistent, continued release leads to ever increasing concentrations in the environment,

corresponding to increased likelihood that that once adverse effects are identified, clean-ups will be

necessary.

When extremely persistent compounds are released to the environment, it takes

considerable time, effort, and money to remediate the pollution. The best management approach to

highly-persistent compounds in the environment is to prevent their use and release whenever

possible.

Resources: This effort requires legislative action but would require no additional resources to

propose or implement; implementation may even result in resource efficiencies.

Establish authority to request data regarding contaminants of potential environmental concern

Data gaps in PFAS research limit the ability to understand exposure levels in the environment, quantify

toxic levels for humans or wildlife, and identify parties responsible for contamination. Authority to

request information from entities on compounds in products would aid the MPCA and other agencies in

closing the data gaps. The agency could collect information (documents, testimony, written responses to

questions) related to the facilities’ activities or activities of the entities in the facilities’ supply chain. This

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authority would not require any additional regular reporting by industries or entities, but it would allow

MPCA to collect information in a timely manner when concerning levels of environmental pollution are

found, including information that would identify sources of PFAS contamination. See the Quantifying

PFAS Risks to Human Health Issue Paper for discussion of how this authority would also be relevant to

conducting future toxicity assessments.

Work status: requires legislative action

Leaders: MPCA Safer Chemicals Unit. Partners: MDH Health Risk Assessment Unit.

Benefits: The authority, would help MPCA identify sources of these contaminants faster, reduce or

prevent contamination including contamination of drinking water, and improve the overall health of

Minnesotans and the environment.

Challenges:  This authority would allow MPCA to request information from entities, but some crucial

data gaps, such as gaps in toxicity information, may not be filled by requesting data from entities

using or producing PFAS. Additionally, this authority would help MPCA respond to PFAS

contamination.

Resources: Enacting this authority would not require significant resources. It may save MPCA and

other agencies future efforts if they could acquire desired information directly from companies,

instead of having MPCA and other agencies recreate studies, techniques, etc.

Develop additional tools for PFAS clean-ups

Develop soil to groundwater leaching values for PFAS to be used in clean-ups and disposal guidance

PFAS have been shown to be highly mobile in soil and in groundwater once they have been released into

the environment. Investigations of PFAS groundwater contamination have demonstrated that

uncontrolled soil releases of PFAS can result in impacts on groundwater. The leaching potential of toxic

chemicals to groundwater is an important factor when evaluating risks posed by releases at remediation

sites. Soil leaching values (SLVs) are risk-based values developed to estimate risk to groundwater via the

soil-to-groundwater leaching pathway. A SLV estimates the concentration of a chemical in soil that will

not result in leaching of that chemical to groundwater at concentrations greater than the compound’s

groundwater risk criteria. In Minnesota, risks posed by ingestion of drinking water are evaluated using

promulgated Health Risk Limits (HRLs) or Heath Based Values (HBVs), developed by the MDH. The MDH

has developed HBVs or HRLs for five PFAS: PFBS, PFBA, PFHxS, PFOA, and PFOS. These values are

available on the MDH’s Human Health-Based Water Guidance Table.

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Currently, no SLVs have been developed for any of the PFAS often found at environmental release sites.

Reasons that SLVs have not been developed for PFAS include 1) the lack of guidance for developing

leaching PFAS values by the EPA or other national organizations; 2) the rapidly evolving understanding of

PFAS fate and transport chemistry; 3) the limited number of PFAS with groundwater risk criteria due to a

lack of oral toxicity data. Appropriate chemical and physical information would need to be collected to

develop SLVs for the five PFAS for which HBVs are available and be prepared to develop additional PFAS

SLVs as additional drinking water criteria or standards are developed. The data required to develop SLVs

are reliable published estimates of soil adsorption coefficients (K

, defined as the amount of a

substance that is absorbed onto soil per volume of water) and drinking water criteria.

Work status: under consideration

Leaders: MPCA Remediation Division. Partners: MPCA Environmental Outcomes and Analysis, MDH

Drinking Water Protection.

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MDH. (n.d.) Human Health-Based Water Guidance Table. Retrieved from:

https://www.health.state.mn.us/communities/environment/risk/guidance/gw/table.html

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Benefits: There are many scenarios where SLVs would be helpful tools for making decisions. The

application of SLVs at PFAS release sites would provide risk-based tools to estimate what

concentrations of PFAS soil contamination should be remediated and what potentially could remain

in the soil without posing a risk to surrounding groundwater. Similarly, SLVs could be used to help

make decisions about options for disposing of impacted soils. The use of SLVs can provide

justification for soil response actions intended to prevent additional groundwater contamination.

SLVs can provide an additional risk-based tool to require necessary soil cleanups to minimize future

PFAS groundwater contamination.

Challenges: The unique physical and chemical properties associated with the PFAS family of

compounds makes developing of SLVs more difficult. SLVs are generally calculated using K

constants, but K

for PFAS can vary widely depending on the conditions of the measurements.

Though many K

values are available for PFAS, expert consideration is needed to determine

representative K

values for soil types and conditions common in Minnesota or present at a given

site. Additionally, several states and the EPA are developing models for PFAS that estimate leaching

from soils and biosolids, and these models should be considered for development of PFAS SLVs in

Minnesota. Collaboration with these groups (EPA, partner states, Interstate Technology and

Regulatory Council [ITRC]) will be helpful in assessing the state of the science regarding PFAS fate

and transport in soils. Risk-based values for drinking water are also needed for any pollutant to

support derivation of an SLV.

Anticipated resource needs: This effort will require staff time to develop SLVs.

Update guidance for recommended analyte sampling at clean-up sites to include PFAS

MPCA has existing guidance for investigations at Brownfields sites that includes recommendations for

analytes to measure given various activities that may have occurred at the site.

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This guidance

document, last revised in April 2001, does not include guidance on when it is advisable to sample soil,

water, or air for PFAS. At a price of $300-$400 per sample, PFAS sampling is expensive, and voluntary

participants in the Brownfields program or responsible parties in the Superfund program are hesitant to

sample for PFAS when PFAS may not be present at levels of concern. An ongoing initiative at MPCA is

the Pilot PFAS Inventory, which has gathered data on which industries are known or likely to use PFAS.

Revising the site investigation methodology to leverage the information gathered by the Pilot PFAS

Inventory will inform MPCA and partners about when it is strategic to sample for various PFAS and in

which media (water, soil, biota, air). This project proposes initiating a workgroup of scientists and

project managers from MPCA to update the existing guidance document to include both

recommendations of when to sample for PFAS and other emerging contaminants as well as

recommended sampling strategies. This guidance might take the form of a flow chart or other decision-

making tool to ensure that consistent, science-based decisions about PFAS sampling at potential

remediation sites (whether for the Brownfield or Superfund program) are being made across sites and

programs.

Work status: under consideration

Leaders: MPCA Remediation Division. Partners: MPCA Environmental Analysis and Outcomes.

Benefits: This project would help ensure that potential PFAS contamination is not overlooked at

clean-up sites and appropriate health-protective actions are taken.

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MPCA. (2001). Minnesota Pollution Control Agency Voluntary Investigation and Cleanup, Guidance Document #11. Retrieved

from: https://www.pca.state.mn.us/sites/default/files/vic-gd11.pdf

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Challenges: The lack of requirements mandating reporting of PFAS releases, labeling PFAS in

products, and handling or disposing of PFAS waste means that there is much unknown about which

industries use PFAS, which PFAS they use, and how much PFAS they are likely to discharge to soil,

water, and air. The guidance may have to be regularly updated to incorporate new knowledge of

likely PFAS sources.

Resources: Updating this guidance would likely require effort by a team of staff from MPCA.

Explore opportunities to supplement the state Remediation Fund

There are many businesses across Minnesota that have historically used PFAS products and may have

discharged PFAS at levels that are now identified as harmful to human health and the environment. Car

washes using PFAS in waxes and polishes, textile companies using PFAS coatings, paper production

companies, and firefighting training centers using PFAS-containing foams are just some examples of

facilities that may have significant liability stemming from PFAS releases. There are potentially

thousands of industrial and commercial sites around Minnesota with ongoing or historic PFAS releases

that may be impacting drinking water and aquatic ecosystems. In some number of PFAS-contaminated

sites, there may not be a responsible party available to pay for remediation and the costs associated

with remediation would instead be borne by the state’s Remediation Fund. It is unknown how many

PFAS-contaminated sites are present in Minnesota that do not have responsible parties available to pay

for site’s remediation. This project would investigate the potential costs and benefits of various

strategies for supplementing the state’s Remediation Fund to account for increased financial stress from

PFAS sites without responsible parties available to pay for investigation and clean-up.

Work status: under consideration

Leaders: MPCA Remediation Division.

Benefits: Planning for potential strains on the Remediation Fund stemming will allow MPCA to

respond in a timely manner to PFAS-contaminated sites into the future.

Challenges: It is currently difficult to determine how many sites are likely to be discovered in

Minnesota without responsible party’s available to fund remediation activities. This may challenge

the planning process.

Resources: Investigating the potential to develop a PFAS fund program would require staff resources

from MPCA and likely also the Minnesota Department of Commerce.

Overview of intersectional issues

 Quantifying PFAS toxicity: Communication with the public and understanding the

potential health impacts of PFAS exposure are key to ensuring protection of human health,

welfare, and the environment. Health-based guidance values, however, require data on toxicity

and exposure that are not available for the vast majority of all the PFAS found in the

environment. (See the Quantifying PFAS Risks to Human Health Issue Paper for more

information on challenges stemming from PFAS toxicity data limitations.) 

 Managing PFAS in waste streams: Remediating PFAS sites results in PFAS contaminated media

that requires disposal. Guidance is needed on when waste from clean-up sites, like soils with

detectable PFAS, can be passed to landfills and when these materials should be further treated

or disposed of in a hazardous waste landfill or hazardous waste incinerator. Even without

acceptance of waste generated from remediation sites, landfill leachate, effluent and biosolids

from wastewater treatment plants, and contact water from composting facilities all contain

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PFAS stemming from industrial and commercial uses of PFAS-containing products and need to

be addressed appropriately. Additional considerations will be needed to ensure appropriate

regulations are in place to address safe handling and disposal of PFAS-containing products.

 Protecting Minnesota wildlife: The limited data available for a limited number of PFAS currently

indicate that health-based values protecting humans from PFAS exposure in drinking water and

from fish consumption are more stringent than benchmarks that are protective of wildlife;

therefore, remediating PFAS-contaminated sites to protect against adverse effects in humans

likely also results in protective concentrations for wildlife for those PFAS. However, ongoing

review of wildlife research is needed to ensure that continuing research supports that

conclusion and that these conclusions are also valid for currently unstudied PFAS.

 Developing and expanding access to analytical methods: Analytical methods for PFAS are

expensive and time-intensive to run, and include only a subset of all PFAS that may be occurring

in drinking water – see the Measuring PFAS Effectively and Consistently issue paper for more

information on the costs and challenges associated with measuring PFAS in various matrices.

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Managing PFAS in e

Background

 The term “waste” encompasses the things that we “throw out” or “wash down the drain” after they

are no longer useful. Facilities collecting this waste, like composters, landfills, and wastewater

treatment plants (WWTP), also produce end products from treatment or disposal operations that

must be managed, such as leachate from landfills or biosolids from a WWTP.

 State and federal regulatory programs -- including the RCRA, the Clean Water Act (CWA), the Clean Air

Act (CAA), and Minnesota Solid Waste Rules -- ensure that all waste is handled in a manner that

minimizes damage to human health and the environment.

 Per- and polyfluoroalkyl substances (PFAS) pose challenges to our existing waste management

systems. PFAS are persistent in the environment, ubiquitous in commercial and industrial products,

resistant to destruction, and often harmful to people at low doses. There is not guidance regarding

disposal of PFAS-containing waste.

 Monitoring of PFAS in leachate, ash, effluent, and biosolids shows that though these facilities do not

use or produce PFAS, they can serve as a conduit for waste streams containing high concentrations of

a diversity of PFAS. PFAS are often passed through to effluent, leachate, ash, and biosolids – the

management of these pass-through end products can result in PFAS releases to the environment.

 Managing waste with PFAS is challenging because PFAS are resistant to degradation, causing them to

cycle between environmental media and waste management facilities.

 Treatment technologies used to remove PFAS create new, concentrated PFAS end products,

which then need to be destroyed or landfilled. If PFAS are not completely destroyed, some PFAS

will be released into the environment.

 Treatment or destruction is more difficult and expensive when pollution is diffuse or combined

with other co-contaminants -- treating leachate or effluent is generally more costly than treating

concentrated PFAS waste from an industrial facility.

 Manufacturers are not required to disclose if or how much PFAS are present in products, making it

difficult to track down sources of PFAS in waste streams.

 Due to the propensity for PFAS to cycle through waste management facilities and the environment,

the most strategic approach is to prevent PFAS from entering waste streams (see the Preventing PFAS

Pollution issue paper).

What is Minnesota doing now?

 Monitoring: MPCA partnered with landfills, composting facilities, and WWTPs to conduct voluntary,

one-time monitoring for PFAS (funded by MPCA). MPCA has also monitored for PFAS in the landfills

managed by the CLP. If drinking water impacts are discovered during monitoring, MPCA takes remedial

actions to reduce PFAS concentrations in drinking water to below the health-based values determined

by MDH.

 Research: MPCA has approved a demonstration research project on landfill leachate treatment that is

designed to remove PFAS before discharging treated leachate to a stormwater pond.

 Regulation: MPCA has required landfills and composting facilities land-applying leachate to monitor

for PFAS. MPCA has issued site-specific Water Quality Criteria (WQC) for PFOS protective of fish

consumers applicable to waterbodies with known PFOS surface water contamination – this will affect

permittees discharging effluent to those waters.

Managing PFAS in waste

Summary

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What are remaining gaps and opportunities for action?

 Gap: Research is needed to understand the fate and transport of PFAS in land-applied biosolids and

define the extent of known PFAS groundwater plumes at CLP sites.

 Opportunity: MPCA could conduct a study to evaluate the fate and transport of PFAS contained in

land-applied biosolids, which could provide the data needed to develop tools for making reasonable

and responsible decisions regarding land-application of biosolids with detectable levels of PFAS.

 Opportunity: Initial investigation of groundwater at closed landfills in the CLP showed PFAS levels

exceeding health-based values at 55 locations – sometimes by a large margin. Access to funding

sources would allow MPCA to fully investigate PFAS plumes to determine if remedial actions are

needed.

 Gap: WWTPs, landfills, and composting facilities have struggled to identify and reduce PFAS sources to

their facilities.

 Opportunity: Identifying and reducing PFAS inputs to waste management facilities is a challenge. To

address industrial sources, MPCA could support monitoring and discussions between WWTPs and

their industrial PFAS sources, leveraging data from the industrial pre-treatment program in Michigan.

To address PFAS loading to facilities from consumer products, pollution prevention policies are

needed (see the Preventing PFAS Pollution issue paper).

 Gap: The science and regulatory status of PFAS is complex and rapidly evolving – there is limited guidance

for facilities making management, treatment, and disposal decisions for products containing PFAS.

 Opportunity: MPCA could develop guidance on options available for disposing of unused PFAS-

containing firefighting foam and options for collecting and disposing PFAS-containing wastewater

produced in an emergency.

 Gap: There is a lack of regulation regarding management of PFAS-containing waste.

 Opportunity: Waste management facilities fall under various regulatory programs, and the “first

step” in a process to begin assessment of and reductions in PFAS releases through permit conditions

would also vary. MPCA could consider taking coordinated regulatory actions on PFAS in waste

facilities, including:

 Mandating monitoring of PFAS in groundwater at all permitted solid waste facilities, which

would inform next steps to minimize PFAS in groundwater and surface waters.

 Rulemaking to define PFAS as “hazardous waste” under RCRA, resulting in requirements on

handling, storage, and disposal of concentrated PFAS.

 Mandating monitoring of PFAS in effluent from WWTPs and conducting rulemaking to develop

statewide WQS for PFAS, which would trigger the regular regulatory processes for development

of effluent limits. MPCA would develop a path forward to assess, list, and address PFAS

impairments.

How does this work benefit human health and the environment?

 Reducing PFAS discharges to surface water, groundwater, and soil from waste facilities prevents

harmful exposure to humans and wildlife.

How does this work benefit Minnesota’s economy?

 Treating PFAS at the source rather than in the outputs from (often publicly-owned) waste facilities

places the financial burden with PFAS generators, encouraging innovative pollution prevention

approaches and saving tax-payer money. These actions to limit PFAS releases from the source also

reduce Superfund liability for businesses and the likelihood of costly cleanups.

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Background

The term “waste” generally refers to products and materials at the end of their life – the things that we

“throw out” after they are no longer useful. Most people are familiar with the municipal solid waste

stream. When products we have in our homes are “thrown out,” they leave our homes and are sent to

recycling, composting, a waste to energy facility, or a landfill. Water and sewage from our homes goes

down the drain and ends up at a municipal WWTP or at a soil-based treatment system. Industries also

have both wastewater and solid waste streams. People and businesses rely on private and public waste

facilities to manage and dispose of our waste. Though it can appear that waste simply “disappears,” the

reality is more complicated. Waste treatment systems – including those that deal with solid waste (e.g.

composting, incineration, and landfills) and wastewater – create various end products. Some end

products, such as biosolids or landfill gas, may be beneficially re-used; other end products, such as

landfill leachate, wastewater effluent, or incineration ash, may need to be managed. All end products

could be conduits of pollutants to the environment. Complex systems are at play to ensure that waste is

managed in a way that results in the least possible disturbance to our communities, our environment,

and our health.

PFAS pose challenges to our existing waste management systems – PFAS are ubiquitous in the economy

and the environment, and therefore also in our waste streams. Extensive monitoring in Minnesota and

around the country has found that PFAS can concentrate to high levels at waste facilities, including

those accepting only municipal solid waste (waste from businesses and homes). PFAS are persistent,

meaning that they do not break down in the environment or in traditional treatment systems that may

be applied at waste facilities. Many PFAS will not break down during combustion unless high

temperatures are achieved under optimal conditions – incomplete PFAS combustion products can be

released back to the environment at waste burning facilities. Finally, many PFAS cause adverse health

effects at low doses, and can pose a risk if they are consumed through drinking water, food, or

incidental ingestion of dust and soil. Little is known regarding health risks associated with inhalation of

PFAS.

Regulatory structures for waste management

There are several state and federal regulatory programs that intersect to ensure that waste is handled in

a manner that minimizes damage to human health or the environment.

Resource Conservation and Recovery Act and Minnesota Waste Statutes and Rules

The main federal law for the regulation, handling, treatment, transport, storage, and disposal of waste is

the RCRA, passed in 1976. Minnesota’s parallel waste management statutes, under Minn. Stat. ch. 116

and 115A, establish similar goals. RCRA has provisions relevant to municipal solid waste, hazardous

waste, materials from construction or demolition projects, and underground storage tanks. There are

multiple goals of RCRA, including protecting human health and the environment from the hazards posed

by waste handling and disposal, encouraging recycling and recovery, and reducing the amount of waste

generated. The regulated community that complies with RCRA and its regulations is large and diverse. It

includes facilities typically thought of as hazardous waste generators, such as industrial manufacturers

and laboratories, but also government agencies and small businesses, such as a dry cleaners generating

small amounts of hazardous solvents, or a gas station with underground petroleum tanks.

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RCRA is related to, but distinct from, another law called the Comprehensive Environmental Response,

Compensation, and Liability Act (known as Superfund or CERCLA), which regulates the cleaning-up of

contaminated sites. RCRA regulates materials that are currently destined for disposal or recycling. Both

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EPA. (2014). RCRA Orientation Manual. Retrieved from: https://www.epa.gov/hwgenerators/resource-conservation-and-

recovery-act-rcra-orientation-manual

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programs have enforcement capabilities that allow regulators to assess if a site or facility contains a

hazardous substance that is posing a risk to human health or the environment, investigate the nature of

a violation or spill, evaluate clean-up options, and implement the preferred method of clean-up.

Minnesota has broader hazardous waste rules and regulations. Any business generating waste in

Minnesota is potentially regulated under the Minnesota Hazardous Waste Rules; Minnesota has

received state authorization from EPA that delegates to MPCA the primary responsibility of

implementing the RCRA hazardous waste program. Currently PFAS are not listed as a “hazardous

wastes” under RCRA or the Minnesota Hazardous Waste Rules, but some PFAS-containing materials can

have characteristics of hazardous waste.

Non-hazardous solid waste facilities, including municipal solid waste (MSW) landfills, industrial landfills,

construction and demolition (C&D) landfills, combustor ash landfills, and yard waste or composting

facilities, are also regulated. For example, MSW landfills are required to be located in a suitable

geological area (away from wetlands, flood plains, or other restricted areas), must be lined to protect

underlying soil and groundwater, must collect the water filtrating through the landfill (called leachate)

and properly treat or dispose of it, must be covered with soil, must test surrounding groundwater to

make sure that waste is not leaking through the liner, and landfill operators must maintain the landfill

for an extended period after it has closed.

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At MSW and industrial landfills, leachate is most frequently

disposed of by being sent to a municipal WWTP, but a limited number of MSW facilities land-apply

leachate by spray irrigation to fields owned and operated by the facility. In Minnesota, C&D landfills

have fewer restrictions than MSW and industrial landfills and are not required to be lined. Construction

and demolition debris includes concrete, brick, bituminous concrete, untreated wood, masonry, glass,

trees, rock and plastic building parts, and similar materials. Large-scale composting facilities that accept

food waste and possibly other compostable products are also required to operate on an impermeable

surface and collect water infiltrating the compost, which is called “compost contact water.” MPCA and

local governments are the primary planning, regulating, and implementing entities for the management

of nonhazardous solid waste, such as household garbage and nonhazardous industrial solid waste.

Closed Landfill Program

The Legislature created the CLP to provide resources to manage closed landfills without using the

complex legal-liability framework of the Superfund process. Superfund laws use a “polluter pays” model

to manage and clean-up contaminated sites, but this process is ineffective at dealing with closed

municipal landfills, where the “responsible parties” may be hundreds of businesses and waste haulers

and thousands of residents. Because virtually all Minnesotans create trash, the CLP uses mostly tax

dollars to manage closed landfills and funding from insurance settlements. The CLP was established to

maintain certain mixed municipal waste landfills in the state over the long term. Closed landfills must be

monitored and managed in perpetuity to protect the environment and human health; they produce

leachate and gases that must be managed properly to avoid polluting groundwater or affecting nearby

structures. There are 114 closed landfills eligible for the CLP. Once landfills are enrolled in the CLP, the

MPCA is responsible for their long-term care. The agency contracts with businesses to perform many

services, including mowing, sampling and analysis, operating gas and groundwater treatment systems,

and leachate collection and disposal.

Clean Water Act

The CWA is a federal law passed in 1972 that regulates pollution to surface waters from discharges of

waste. While RCRA frequency regulates solid waste facilities, the CWA tends to focus on management of

treated wastewater called effluent. MPCA regulates entities discharging contaminants to the

environment based on Water Quality Standards (WQS), which are the rules promulgated by Minnesota

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Title 40 of the Code of Federal Regulations (CFR) part 258

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under the CWA framework. Effluent discharge limits for permittees are set to ensure that WQS are not

exceeded. In some cases, site-specific WQC can be developed to address areas of known contamination

or to account for site-specific water quality considerations. Many waste facilities, including WWTPs,

have National Pollutant Discharge Elimination System (NPDES) permits that allow them to discharge

effluent to surface waters in the state or State Disposal System (SDS) permits that allow them to

discharge to land or soil. These permits are renewed every five years to consider new monitoring

requirements or new effluent limits based on applicable WQS or WQC.

WWTPs, the facilities that collect wastewater and sewage from municipal, commercial, or industrial

sources for treatment and disposal, are regulated under the CWA and with NPDES permits. Frequently

these WWTPs are publicly owned. WWTPs act as funnels for all the of pollutants used in commercial,

household, and industrial products that end up flushed down a drain – some of these pollutants can be

treated by the WWTP and removed before effluent or sludge is released from the facility. However,

many pollutants (including PFAS) are not removed through the standard treatment operations at the

WWTP. The CWA allows WWTPs to require commercial facilities and other non-domestic wastewater

sources to remove harmful pollutants before the wastewater is discharged to a municipal sewer

system.

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This “pretreatment program” prevents the introduction of pollutants to public systems that

may pass through public treatment to rivers, lakes, and streams. Pretreatment also prevents discharges

to publicly owned treatment facilities of pollutants that would interfere with facilities’ operations,

including their use and disposal of biosolids or sludge. Generally, WWTPs can enforce pretreatment

requirements of wastewater sources whether or not the WWTP has effluent limits for that contaminant.

In addition to regulating the level of pollutants in the wastewater leaving a WWTP, the CWA also can

regulate the biosolids or sewage sludge produced by the WWTP. Biosolids are the solids that emerge

from a WWTP after treatment – they are beneficial products that, if high-enough quality, can be applied

to fields for use as a soil amendment. Biosolids that are not land-applied to fields are often either

landfilled at a solid waste facility or burned at a sewage sludge combustion site. EPA has regulations on

the levels of various toxics that are acceptable in biosolids that will be land-applied. EPA reviews federal

biosolids standards every two years to identify additional toxic pollutants that occur in biosolids and set

regulations for those pollutants if sufficient scientific evidence shows they may harm human health or

the environment. Currently, there are no limits for PFAS in biosolids. PFAS have been shown to

concentrate in this product; therefore, EPA is currently conducting a risk assessment for PFOA and PFOS

in biosolids and may publish new standards for these contaminants.

Clean Air Act

Confined and controlled burning, known as combustion, can decrease the volume of solid waste

destined for landfills and recover resources and energy from the waste-burning process. Some waste-to-

energy facilities use energy recovered from combustion of solid waste to produce steam and electricity.

While Minnesota emphasizes reuse and recycling, roughly one-fifth of Minnesota’s garbage is used for

energy production. Minnesota currently has seven waste-to-energy plants. Ash left over from

incineration can be used as top cover for landfills or be disposed of inside the landfill. Emissions also

occur from pollutants that volatilize from the landfill. The CAA regulates emissions from MSW landfills

and waste incinerators. However, despite the fact that PFAS has been measured in air emissions from

landfills, because PFAS is not a “hazardous air pollutant” (HAP) under the CAA, there are currently no

requirements for monitoring or controlling PFAS emissions to the air from combustion or volatilization.

Currently there are no air health benchmarks from MDH or from the EPA related to PFAS inhalation

risks, but there are benchmarks developed by Michigan. Air emissions of PFAS may also pose a risk to

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MPCA. (n.d.). Wastewater pretreatment. Retrieved to: https://www.pca.state.mn.us/water/wastewater-pretreatment

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surrounding surface water and soils due to PFAS’s ability to fall back to earth’s surface through rain and

dry deposition. See the

Understanding Risks from

PFAS Air Emissions Issue

Paper for more

information.

Occurrence of PFAS at

various entry points to

the environment

The past and ongoing

activities section of this

paper discusses the PFAS

monitoring that has

already been conducted

in Minnesota at various

waste facilities, but PFAS

monitoring is also

ongoing at waste facilities

across the US For

example, a recent study

of influent, effluent, and biosolids in WWTPs

in Michigan found that many facilities had

elevated levels of PFAS.

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Michigan

summarized the industrial sources of PFOS to

municipal WWTPs, which were identified

through the Industrial Pre-Treatment Program

PFAS Initiative (see Figure 8). Sources were

defined as those industrial users with

discharges to WWTPs above a screening level

of 12 ng/L (this is not a risk-based level). The

majority of significant PFOS sources were

metal finishers, contaminated sites associated

with industries or activities with PFOS usage,

and landfills that accepted industrial wastes

containing PFOS. Michigan has developed a

Municipal NPDES Permitting Strategy for PFOS and PFOA, with the goal of continuing to identify, reduce,

and remove PFOS and PFOA at WWTPs.

Various studies have also measured levels of PFAS in landfill leachate. For example, the USGS recently

published a survey of PFAS releases from municipal landfills across the country.

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This study measured

169

MPART. (2020). Wastewater Treatment Plants / Industrial Pretreatment Program.

https://www.michigan.gov/pfasresponse/0,9038,7-365-88059_91299---,00.html

170

Lang, J.R., Allred, B.K., Field, J.A., Levis, J.W., & Barlaz, M.A. (2017). National estimate of per- and polyfluoroalkyl substances

(PFAS) release to US municipal landfill leachate. Environmental Science and Technology, 41, (4), 2197-2205.

https://doi.org/10.1021/acs.est.6b05005

Figure 8. Summary of industrial sources of PFOS to Municipal WWTPs (Michigan).

Figure 9. PFAS levels in leachate from construction and

demolition landfills, municipal solid waste landfill,

and municipal solid waste ash landfills in Florida.

From Solo-Gabriele et al. 2020.

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70 PFAS in 95 leachate samples, estimating that the total mass of PFAS moving from landfill leachate to

WWTPs in the US was between 562 and 638 kg (5.62 x 10

g – 6.38 x 10

g) in the year 2013. For context,

MPCA estimated that 0.4 - 1 g/year of PFOS emissions associated with a metal plating facility in

Minnesota caused exceedances of site-specific surface water criteria for PFOS and resulted in a “do not

eat” fish advisory in a nearby lake.

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This study also found that the PFAS 5:3 fluorotelomer carboxylic

acid (5:3 FTCA) was the dominant structure present in leachate. 5:3 FTCA is a PFAS degradate of

polyfluroalkyl phosphates, which are used as commercial surfactants, often in the context of food

contact paper and textile coatings. 5:3 Fluorotelomer carboxylic acid (FTCA) in turn further degrades to

PFHpA, PFHxA, and PFPeA.

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In Minnesota, PFHxA has been commonly detected in ambient

groundwater, drinking water, and human biomonitoring studies – MDH has begun a toxicity review of

this compound.

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Another study measured PFAS in leachate from five landfills in Florida, including C&D

landfills, MSW landfills, and landfills containing only MSW ash from combusting municipal waste.

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This

study found that found that C&D landfills had lower levels of PFAS than municipal solid waste facilities,

but still had quite high PFAS levels overall (see Figure 9). This study also found that while leachate from

landfills containing ash associated with waste combustion at municipal facilities had measurable PFAS,

the levels were considerably lower than leachate levels in municipal solid waste facilities.

Breaking the PFAS waste cycle

Figure 10. Schematic diagram of how PFAS could cycle through waste facilities and environmental media.

171

MPCA. (2020, Jan 30). Minnesota Pollution Control Agency’s (MPCA’s) comments on the Addition of Certain Per- and

Polyfuoroalkyl Substances; Community Right-to-Know Toxic Chemical Release Reporting (EPA-HQ-TRI-2019-0375). Available

upon request.

172

Lee, H., D’Eon, J., & Mabury, S. (2010). Biodegradation of Polyfuoroalkyl Phosphates as a Source of Perfluorinated Acids to

the Environment. Environmental Science and Technology, 44, 3505-3310. https://doi.org/10.1021/es9028183

173

MDH. (2020). Nominated Contaminants Status and Information, MDH Drinking Water Contaminants of Emerging Concern

Initiative. Retrieved from:

https://www.health.state.mn.us/communities/environment/risk/guidance/dwec/index.html#cecnom

174

Solo-Gabriele, H.M., Jones, A.S., Lindstrom, A.B., Lang, & J.R. Waste type, incineration, and aeration are associated with per-

and polyfluoroalkyl levels in landfill leachates. (2020). Waste Management, 107, 191-200.

https://doi.org/10.1016/j.wasman.2020.03.034

Minnesota’s PFAS Blueprint • February 2021

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One of the major challenges posed by managing PFAS in waste is how resistant PFAS are to degradation,

causing them to cycle between media and from one waste product to another. PFAS are common in

both wastewater and solid waste. The standard options for handling or treating these wastes do not

remove PFAS. Because of the way these wastes are handled, PFAS may move in between landfills and

WWTPs. Figure 10 illustrates schematically how PFAS may transfer between waste facilities and

environmental media. For instance, municipal wastewater treatment creates effluent and sludge or

biosolids. If there are PFAS in what is coming into the WWTP, there is going to be PFAS in what is leaving

the wastewater treatment plant (unless special treatment is undertaken). Some PFAS will be in the

effluent, but others are known to partition to the biosolids. Biosolids are often used as a beneficial

source of nutrients to soil, so PFAS may travel with land-applied biosolids, potentially resulting in soil,

surface water, groundwater, and crop contamination. If the biosolids are not land-applied, they are

likely to be taken to a landfill or an incineration facility. Incineration of PFAS-containing wastes can emit

harmful air pollutants, such as fluorinated greenhouse gases and products of incomplete combustion,

and some PFAS may remain in the incinerator ash, which is often landfilled. If the landfill has PFAS-

containing materials in it, that leachate will likely contain PFAS. In some cases, that leachate is spray

irrigated onto fields, which can again lead to problematic soil, surface water, and groundwater

contamination. If the leachate is not spray irrigated, it may be sent to a wastewater treatment plan –

and the cycle starts over again.

Another complicating factor is the nature of PFAS treatment. The types of treatments that are used to

remove PFAS from environmental media – air, water, soil – do not destroy the PFAS. Standard

treatments like granular activated carbon (GAC), reverse osmosis, ion exchange resins, or foam

fractionation, create a waste product with a high concentration of PFAS. These PFAS-containing wastes

then need to be disposed of or destroyed. If they are landfilled, leachate may reintroduce some PFAS

back into the environment. While some options to destroy PFAS – such as high temperature incineration

– may be available, they may not destroy all PFAS and some emissions of PFAS may still occur.

Research on the most efficient and cost-effective mechanisms to destroy PFAS is ongoing.

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Effective

treatment and destruction of PFAS is currently technologically challenging and costly. The stability and

other physical and chemical traits of PFAS make many treatment technologies ineffective. Even

aggressive technologies such as thermal treatment and chemical oxidation require extreme conditions

beyond typical in those practices.

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For example, PFAS destruction may require extremely high

temperatures, high chemical doses, or extreme pH to be effective or even partially effective in

destroying PFAS. Though the emerging realization that there will be money to be made in inventing

effective PFAS treatment and destruction technologies has resulted in a boom in research, many new

technologies are bench scale and have not been confirmed to be effective. The standard PFAS treatment

and destruction options available are expensive to set up and maintain. Leachate and other complex

matrixes often require multiple pre-treatment steps before PFAS removal steps, which adds to cost and

time. Many treatment technologies are designed to work most effectively for specific types of PFAS – for

example, GAC filtration is more effective for long-chain PFAS and less effective for short-chain PFAS.

There is a concern that if a treatment regime is installed, it may need to be augmented or replaced if

new PFAS toxicity information indicates that a different PFAS compound should be targeted for

treatment and destruction.

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EPA, Office of the Administrator. (2020, August 25) EPA, US Department of Defense, and State Partners Launch Technical

Challenge Seeking Innovative Ways to Destroy PFAS in Firefighting Foam. [Press release]. Retrieved from:

https://www.epa.gov/newsreleases/epa-us-department-defense-and-state-partners-launch-technical-challenge-seeking

176

SERDP-ESTCP. (n.d.). DoD-Funded Research on PFAS. Retrieved from: https://serdp-estcp.org/Featured-Initiatives/Per-and-

Polyfluoroalkyl-Substances-PFASs/DoD-PFAS-Page/DoD-PFAS-Page

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ITRC. (2020). PFAS Treatment Technologies. Retrieved from: https://pfas-1.itrcweb.org/12-treatment-technologies/

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Treatment can occur at multiple points in the waste process. Waste can be treated for PFAS before it is

sent to a WWTP or landfill. For example, liquid waste from an industrial facility can be treated before it

is sent to a WWTP, or contaminated soils can be thermally treated before they are landfilled. Outputs

from WWTPs (effluent, biosolids), landfills (leachate), composting facilities (contact water), or

incinerators (air emissions, ash) can also be treated before they are released to the environment.

Generally, treatment or destruction is most difficult and expensive when the pollution is diffuse (less

concentrated) and combined with other co-contaminants. For this reason, treating complex matrixes

like landfill leachate or WWTP effluent are generally more costly than treating concentrated PFAS waste

from an industrial facility.

As this section describes, it is difficult to break the cycle of PFAS moving between media and between

waste products. The more strategic approach is to prevent PFAS from entering waste streams as much

as possible. See the Preventing PFAS Pollution Issue Paper for more information on steps MPCA and

others can take to prevent continued PFAS loading to waste facilities and to the environment.

Distinguishing PFAS sources and PFAS conduits

When talking about PFAS in waste streams, it can be helpful to distinguish between “sources” of PFAS

and “conduits” of PFAS. Sources are those where PFAS are produced or manufactured, or industries that

intentionally use PFAS-containing products as part of their processes. These kinds of sources would

generally be industrial-type sources and result in industrial waste streams that carry PFAS. Conduits are

locations where PFAS are not produced or intentionally used, but are released to the environment. PFAS

can be present at conduits because of the occurrence of PFAS in consumer products (perhaps including

those used for some general purposes at the facility) industrial products, or the environment. Waste

facilities – such as WWTPs and or municipal solid waste facilities – are conduits of PFAS. As wastes travel

from our households to final disposal, PFAS travel with the waste stream and are concentrated and

passed through to the environment through wastewater effluent discharge, wastewater biosolids

disposal, landfill leachate, and compost contact water.

In the early 2000s, when PFAS were first discovered in Minnesota, concern was focused on PFAS sources

– areas where PFAS or PFAS-containing products had been manufactured and the resulting waste

streams had high levels of PFAS. However, increased understanding of PFAS toxicity over time has led to

the realization that lower levels of PFAS, especially more bioaccumulative PFAS, can also have adverse

health impacts. That understanding means that levels of PFAS in materials emitted or discharged from

waste facilities – as conduits of PFAS to the environment – are now considered levels of concern.

Responsible environmental stewardship of PFAS will require management of PFAS in waste streams.

While PFAS impacts from both sources and conduits will likely need to be considered, the approaches

will need to be different at sources than at conduits. Differences between PFAS at sources and conduits

include differences in the concentrations of PFAS in waste and differences in the diversity of PFAS

present. Pollution prevention approaches, potentially including phasing-out PFAS in certain non-

essential uses for commercial products and industry, would reduce sources of PFAS into the facilities

that are conduits of PFAS to the environment in the future. However, the quantity of PFAS-containing

products already in circulation in households, businesses, and factories around the state may require

additional source reduction actions at waste facilities.

Past and ongoing efforts

The MPCA has compiled monitoring data from many types of waste systems, including some WWTPs,

landfills, large subsurface treatment systems, and composting facilities. The data collected include

samples of influent, effluent, sludge, leachate, groundwater, and air. MPCA has also worked with one

landfill to research and pilot a potential leachate treatment system for PFAS. Finally, MPCA has taken

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some regulatory actions with respect to PFAS in waste: MPCA has required PFAS monitoring in

groundwater and leachate at active landfills that land-apply leachate and MPCA has issued a site-specific

WQC for PFOS, which will correspond to the regular regulatory steps associated with NPDES and SDS

permits. The following sections describe these efforts in more detail.

Voluntary monitoring

Monitored for PFAS at all major municipal WWTPs

From 2007 to 2010, PFAS monitoring was completed at all major WWTPs (meaning any plant with

treatment design flows greater than 1 million gallons per day) throughout the state. The first set of

sampling at WWTPs occurred from 2007-2008. This sampling included measurements of 13 PFAS in

influent, effluent, and sludge at 28 municipal and industrial WWTPs. The data from this sampling effort

were published in an appendix to the document “PFC’s in Minnesota’s Ambient Environment: 2008

Progress report.”

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This was a voluntary effort and was carried out at no cost to the WWTPs.

The results of this monitoring showed elevated levels of multiple PFAS at multiple WWTPs. At the time

that this effort was undertaken, there were no available screening levels for PFAS in sludge, and health-

based benchmarks for human toxicity were higher than they are today. However, levels of PFAS in

influent, effluent, and sludge at the Brainerd facility drew concerns that there was an unknown

significant industrial source of PFAS to the facility. Further investigation led to the discovery that a

chrome plating facility was contributing to PFAS loading at the WWTP. In 2007, the industrial facility

switched to use non-PFOS products. Further investigations into PFAS levels in the Mississippi River

downstream of the WWTP discharge location found that while PFAS levels at the discharge location in

the Mississippi were elevated, concentrations downstream of the discharge were below detection for all

PFAS except PFNA, which was detected one time. MPCA also investigated PFAS levels in fish caught in

the Brainerd area on the Mississippi River, and found PFOS in bluegill, smallmouth bass, walleye, and

northern pike. The average concentrations in those species ranged from 7-13 ng/g.

A second round of PFAS influent, effluent, and sludge monitoring at WWTPs was conducted from 2009-

2010. This sampling included 22 locations in the Metro Area and 67 locations in Greater Minnesota. The

results of this study have not been published but are available upon request. Overall, PFOS levels in

effluent ranged from non-detect (ND) to 153 ng/L, PFOA levels ranged from ND to 667 ng/L, PFHxS levels

ranged from ND to 365 ng/L, PFNA ranged from ND to 70 ng/L, and PFBA ranged from ND to 48,100

ng/L. PFAS were detected in influent, effluent, and sludge at high rates in both Metro region WWTPs

and WWTPs located in Greater Minnesota.

Work status: completed

Leader: MPCA Municipal Division. Partners: Participating WWTPs.

Benefits: This monitoring effort identified the baseline levels of PFAS in influent, effluent and

biosolids at a sample of municipal WWTPs. Having this information will be important in measuring

improvements in PFAS levels over time, as source reduction and other efforts are undertaken. As a

result of this study, some source identification and reduction steps were taken immediately, which

lead to a decrease in PFAS releases.

Challenges: With many facilities participating in this monitoring effort, it was challenging to

coordinate times for staff to collect samples. It was also challenging to train the many MPCA staff

sample collectors to ensure that there was no PFAS contamination. Some facilities were hesitant to

participate in the monitoring effort due to concerns over future regulatory actions. When facilities

tried to identify sources of PFAS into their plants, some described the experience as “like chasing a

ghost” due to the difficulties associated with finding information on which products contained PFAS

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MPCA. (n.d.) PFAS studies and reports. https://www.pca.state.mn.us/waste/pfas-studies-and-reports

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and at what levels. These facilities were discouraged that despite significant effort to find and

reduce PFAS sources, they were not seeing meaningful reductions in PFAS levels in influent or

effluent.

Resources: The MPCA covered the costs of all sampling analysis (over $250,000) as well as the staff

time to collect samples and process the information that was collected.

Monitoring for PFAS at six Large Subsurface Treatment Systems

Large Subsurface Treatment Systems (LSTS) are subsurface disposal treatment systems designed to treat

more than 10,000 gallons of wastewater per day and discharge to groundwater through soil – these

facilities are permitted using the SDS. The MPCA has permitted over 100 LSTS systems. In this PFAS

sampling effort, grab samples were collected at six LSTS facilities: Lake Shore WWTP, Marine on St. Croix

WWTP, Whispering Ridge, Clearwater Harbor Sewage Treatment Plant, Backus WWTP, and Rockwood

Estates WWTP. The facilities sampled were chosen based on record of operation, flow, and treatment

type. Wastewater flow at the sampled LSTS facilities consisted mainly of residential waste. Some of

these facilities received commercial flow, but little, if any, from any industry. Samples were collected in

spring 2011 and analyzed for 13 PFAS -- influent wastewater, effluent wastewater, up-gradient

groundwater, and down-gradient groundwater were sampled at each facility. Samples of the solids

accumulated in the tanks were not taken. The results of this study were not published, but are available

upon request.

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The study found that PFAS were detectable in influent and effluent at all facilities. PFAS were detected

in down-gradient groundwater wells at three locations. PFAS were detected in up-gradient wells at two

locations. The highest PFOS concentration in groundwater was 5 ng/L, and the highest PFOA

concentration in groundwater was 10 ng/L. PFBA, PFPeA, PFHxA, PFHpA, and PFBS were also detected in

down-gradient groundwater. These values do not exceed MDH’s current health-based guidance values.

Work status: completed

Leader: MPCA Municipal Wastewater Division. Partners: Participating LSTS.

Benefits: Although this was a relatively small sampling effort (capturing six of the over 100 LSTS

facilities in Minnesota), the results help provide context for the range of PFAS levels in largely

residential LSTS systems. Overall, the lower PFAS levels observed in LSTS systems compared to major

WWTPs accepting municipal and industrial waste helped prioritize efforts to understand PFAS levels

in WWTPs.

Challenges: This effort had similar challenges to the WWTP monitoring effort described above – it

was important to train samplers to ensure that there were no opportunities for PFAS contamination.

Gaining access to groundwater wells was challenging in a few instances due to snow.

Resources: This effort was funded with grant money ($10,000) for analysis of samples. MPCA staff

collected the samples.

Monitored PFAS in leachate, groundwater, and gas at active landfills

From 2006 through 2009, MPCA’s Solid Waste Section conducted an investigation to evaluate the nature

of PFAS in various waste streams generated at 41 solid waste facilities in Minnesota. This investigation

included MSWs, waste combustion facilities, industrial landfills, and construction and demolition

landfills. Sampling included leachate (when the facility was lined, including leachate from combustor ash

landfills), down-gradient groundwater, up-gradient groundwater, and landfill gas condensate (at gas-

energy facility). Sixteen PFAS were included for analysis.

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Office memo: FINAL REPORT: PFC Sampling at LSTS Systems

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The results of this study showed that all sampled facilities had detections of PFAS in leachate. The

maximum concentration in leachate for PFOA was 84,000 ng/L, for PFOS was 31,000 ng/L, for PFBA was

25,000 ng/L, for PFBS was 15,000 ng/L, and for PFHxS was 12,000 ng/L. Facilities with the highest

concentrations tended to be those that accepted PFAS waste from 3M. While many groundwater

monitoring samples resulted in non-detectable PFAS, several samples had PFAS levels above

intervention limits and above current health-based values from MDH. Detection limits for PFAS have

decreased since this effort was undertaken in the 2000s. The maximum concentration in groundwater

for PFOA was 840 ng/L, for PFOS was 71 ng/L, for PFBA was 26,000 ng/L, for PFBS was 58 ng/L, and for

PFHxS was 140 ng/L. For facilities with multiple up-gradient and down-gradient measurements of PFAS,

statistical analysis was completed to determine if the concentrations down-gradient were higher in a

statistically significant manner than PFAS found in up-gradient monitoring wells at the landfill – in most

instances, PFAS levels in down-gradient monitoring wells showed a statistically significant higher

concentration than up-gradient monitoring wells at the facility. This statistical analysis is available upon

request.

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Landfill gas resulted in detectable PFAS at every sampling location. After this study was

undertaken, MPCA began requiring landfills that land-apply leachate to annually monitor for PFAS in

leachate and in down-gradient groundwater.

Work status: ongoing, initial monitoring completed

Leader: MPCA Solid Waste Section. Partners: Solid waste landfill operators.

Benefits: The result of the investigation led to an understanding of the nature of PFAS in landfill

leachate from various landfill systems (MSW, industrial, C&D, and combustor ash), and the impacts

these facilities may be having on groundwater quality.

Challenges: At the time of this effort, limited information was available for measuring PFAS in gas

condensate. MPCA partnered with SGS AXYS Laboratories to develop a method for this

measurement and conduct analyses.

Resources: The MPCA Solid Waste Section funded the investigation through internal funds (over

$250,000) at the MPCA.

Monitored PFAS in composting contact water and investigated potential upstream sources

This project aimed to better understand PFAS composition and concentrations in contact water

collected at composting facilities – both those that collect source-separate organic material (SSOM)

from household waste and those that collect only yard waste. Composters that accept food scraps and

compostable products are required to collect and treat contact water (water that has come in contact

with organic material during the early stages of composting). Most SSOM compost facilities manage

their contact water by collecting it in a pond and then sending it to a WWTP. In some cases, the contact

water can be land applied through spray irrigation. If contact water is land applied, the levels of

pollutants must meet solid waste intervention limits, defined as a quarter of the health risk limit or

health based value. MPCA worked with seven facilities (five of those facilities collected food and yard

waste and two collected only yard waste) from fall 2018 to spring 2019. Contractors conducted three

contact water pond sampling events at each site. A total of 88 samples were collected, including 59

primary environmental samples and 29 quality assurance/quality control samples. These samples were

analyzed for 29 PFAS.

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MPCA. (2009). Statistical Analysis of PFC data collected by the Open Landfills program. [Memo].

Minnesota’s PFAS Blueprint • February 2021

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The results of the study have been published in a report, available on MPCA’s website.

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The study

confirmed the presence of one or more PFAS in contact water at concentrations above intervention

limits at all SSOM and yard waste sites sampled. At every compost site in the study, at least one

sampling event revealed a PFAS that was over the applicable solid waste intervention limit. At the SSOM

facilities, the detected PFAS included PFBA, PFPeA, PFHxA, PFHpA, PFOA, PFNA, PFDA, PFBS, PFHxS and

PFOS. For the yard waste sites, the detected PFAS included PFBA, PFPeA, PFHxA, PFOA, PFBS, PFHxS, and

PFOS.

Based on these conclusions, an additional literature review was conducted by a contractor, aiming to

find major feedstock contributors to PFAS at compost facilities and identify data gaps. The review

suggests that food contact materials (including compostable products) could be a significant contributor

to PFAS at compost sites. The study notes there is a lack of research on PFAS in yard waste and

recommends that evaluating potential ambient sources near compost sites or feedstock sources should

be a priority. The full literature review will be published on MPCA’s website in early 2021.

Work status: completed

Leader: MPCA Solid Waste Section. Partners: Participating composting facilities, Wood Environment

& Infrastructure Solutions, Inc., SGS AXYS Laboratories

Benefits: The MPCA requires compost facilities test for PFAS in contact water in order to land apply

that contact water, which is a more affordable operational strategy than sending the contact water

to a WWTP. MPCA suspected that PFAS concentrations would be low or non-detect in contact

water. The results of this investigation were surprising and helped identify areas for further

research. Compost sites have environmental benefits and the MPCA is committed to helping sites

succeed. Mitigating PFAS from entering sites and treating contact water for PFAS will help preserve

the operational viability of compost sites. Partnerships with compost facilities will continue to help

the agency facilitate creative and collaborative efforts to reduce PFAS discharges in the future.

Policy and research recommendations are discussed in both the contact water study and the

subsequent literature review.

Challenges: SGS AXYS Lab encountered difficulties in analyzing the samples due to the presence of

very fine suspended particulate matter within the aqueous portion of most samples received. The

suspended particulate matter could not be sufficiently removed prior to analysis using

centrifugation or allowing the samples to settle out prior to filtration. All data was still validated

with qualifiers noted in the report. Subsequent sample sizes were adjusted and lab methods were

updated to ensure better results.

Resources: This study involved two MPCA staff directly overseeing the project, and two additional

staff providing technical expertise. The contact water study cost approximately $35,000 in lab

analytical fees and an additional $42,000 for contractor support (Quality Assurance Project Plan

development, collecting/processing samples and reporting). It took approximately one year to

complete both sampling and report publication.

Monitored for PFAS in groundwater down-gradient of closed landfills

The MPCA owns or oversees 110 closed landfill sites through the CLP. Many of these sites were

established before regulations on landfills related to lining -- landfills in the CLP include landfills that are

unlined, lined in one of the cells, or fully lined. In 2006, MPCA conducted sampling for PFAS in

groundwater down-gradient of the landfills and in leachate in a small number of closed landfills.

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MPCA. (n.d.). Composting and PFAS. Retrieved from: https://www.pca.state.mn.us/waste/composting-and-

pfas#:~:text=MPCA%20recommendations&text=For%20consumers%3A%20Continue%20composting!,composting%20has%20m

any%20environmental%20benefits

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Figure 11. PFAS levels in down-gradient groundwater wells at CLP sites.

Early results of this sampling

were included in a 2006

report to the Senate

Environment Committee,

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but the bulk of the initial

PFAS sampling at CLP sites

began in 2009, when the

agency investigated

groundwater and leachate

at roughly 30 CLP sites.

From 2009 to 2018, PFAS

sampling of groundwater

and leachate was conducted

at a small set of sites each

year, as funding allowed. In

2018, CLP created a goal to

sample all 110 CLP sites for

PFAS at least one time.

Currently, PFAS testing has

been completed at 101 of

the 110 CLP sites. A

summary of the analytical

results for emerging

contaminant monitoring at

landfills, published in May

2020, is available on MPCA’s

website.

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To date, PFAS

has been detected in

groundwater at 98 of the

101 tested sites.

Groundwater levels

exceeded MDH’s HBVs in

groundwater at 55 of those sites. Levels of PFOA and PFOS as high as 30,000 ng/L and 20,000 ng/L

respectively have been detected in shallow groundwater wells.

The CLP has taken several remedial actions at sites due to detected PFAS levels. At the Washington

County Landfill, a triple liner system was installed, along with other work (see Remediating PFAS

Contaminated Sites Issue Paper). At several other sites, drinking water wells located down gradient of

the site were tested to determine if PFAS plumes were impacting private drinking water wells at levels

exceeding health-based values. In several instances, drinking water was found at levels above HBVs, and

the CLP purchased and maintains point-of-use water filters for those homes. In other instances, the CLP

provided funds to dig a new drinking water well into a deeper aquifer without PFAS contamination. At

this time, CLP has focused on sampling drinking water wells and not wells used for agriculture. Ongoing

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MPCA. (2006). Investigation of perfluorochemical (PFC) contamination in Minnesota, phase one.

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MPCA. (2020). Evaluation of Emerging Contaminant Data at Solid Waste Facilities. Retrieved from:

https://www.pca.state.mn.us/sites/default/files/Evaluation-of-Emerging-Contaminant-Data-at-Solid-Waste-

Facilities_02132020.pdf

Minnesota’s PFAS Blueprint • February 2021

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sampling of groundwater around these facilities would help determine the extent and location of PFAS

plumes and determine the need for additional remedial actions.

Work status: ongoing, additional funding needed to investigate sites with high PFAS levels

Leaders: MPCA Closed Landfill Program.

Benefits: CLP has collected a large amount of PFAS data that can aid in different types of research.

Due to CLP sampling, more is known about closed landfills as a potential source of PFAS

contamination. CLP is tracking the PFAS contamination around the landfills and alerting residents of

the potential risk. CLP reduces risks of PFAS exposure by testing domestic wells around landfills for

PFAS and providing treatment systems as needed.

Challenges: PFAS are present in the leachate and groundwater at most of the closed landfills in the

CLP. Most of the sites in the CLP do not have any type of liner beneath the waste and waste is often

in direct contact with the groundwater below. Digging up the waste and placing it on top of an

engineered liner is an expensive, large scale project. Although remedial action has taken place at

several sites with high PFAS concentrations, PFAS is still present in the groundwater at those sites.

Funding has not been available to fully investigate all sites with high PFAS levels. Remedial action,

increased sampling, and plume delineation is needed at most of the sites with PFAS exceedances in

order to help minimize PFAS exposure. Funding has been reduced during fiscal year 2021 and many

PFAS investigations are on hold.

Resources: CLP sites will need to be managed long into the future. As more new contaminants are

identified at the closed landfills, such as 1,4-dioxane and PFAS, there will be a need for site

investigations, sampling, and remedial actions for many years to come. Adequate staffing and

funding are essential to allow the CLP to effectively manage sites. The cost of sampling monitoring

wells and drinking water wells for PFAS is a large yearly expense; it can range anywhere from

$100,000 to $300,000.

Research

Approved Demonstration Research Project for a PFAS leachate management system

Demonstration Research Project (DRP) refers to a limited-scale project designed to promote new

methods of solid waste management. It is designed to obtain new scientific or other information about a

specific method for managing solid waste. In 2015, the Kandiyohi County Landfill was issued a DRP

agreement from MPCA to pilot the application of a proprietary landfill leachate treatment system

developed by Clark’s Technology called LEACHBUSTER. This technology includes multiple filter systems

to remove PFAS and other constituents from leachate – it discharges 90% of the leachate volume as

“clean water” and 10% as “dirty water.” In this pilot, the “clean water” is further passed through a

“boron finishing” treatment system to remove excess boron and discharged to a stormwater pond that

infiltrates to groundwater. The “dirty water” is introduced into the landfill. Kandiyohi County has

collected samples at the influent and effluent of the pilot system and used EPA Method 537 to monitor

for PFBS, PFHpA, PFHxA, PFNA, PFOS, and PFOA. After leachate moved through the treatment system,

PFAS levels were non-detectable for all PFAS except PFOA, which was detected at 3.7 ng/L (below the

intervention limit of 8.75 ng/L) in one sample. Currently Kandiyohi County Landfill sends its leachate to a

WWTP and is testing this leachate system on a subset of the leachate at the plant. The landfill will

continue sampling for many analytes, including PFAS, in the effluent from the LEACHBUSTER system on a

quarterly basis and reporting that data to the MPCA.

Work status: ongoing

Leaders: MPCA Solid Waste Division and Kandiyohi County Landfill.

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Benefits: Managing elevated PFAS levels in leachate is a challenge that will only grow more complex

if WWTPs reduce upstream sources of PFAS by limiting the leachate they are willing to accept from

landfills. By conducting DRPs, landfills like Kandiyohi County gain an understanding of the efficacy of

various leachate treatment systems that could be leaned on in the future to control PFAS levels in

leachate.

Challenges: Operating and maintaining the equipment used in the DRP is costly. At between $300-

$400 per sample, PFAS monitoring to ensure the treatment system is effectively removing PFAS is

also costly.

Resources: DRPs are paid for by the facility looking to investigate the new technology or

management strategy – MPCA provides some technical assistance and oversight.

Regulation

Developed site specific Water Quality Criteria for PFOS

WQC are site-specific surface water values that are applied to address pollution in areas of known

surface water contamination. These WQC are different than WQS in that they do not apply to the entire

state, only to waterbodies explicitly included in the criteria. WQC are developed based on methods and

authorities in state statute and the federal CWA (see Minn. R. ch. 7050). Once a WQC is in place, permits

that are being renewed or newly issued will be evaluated to determine what monitoring requirements

are appropriate. Based on the discharges reported through monitoring, MPCA would determine if there

is a reasonable potential that the facility can cause or contribute to an exceedance of the WQC. If so,

effluent limits would be established and variances may be considered.

In October 2020, MPCA released a new PFOS WQC that applied to targeted waterbodies including Lake

Elmo and connected waterbodies in the Project 1007 corridor in Washington County. When deriving

WQC for those sites, MPCA also took the opportunity to update existing WQC for PFOS elsewhere in the

state (Bde Maka Ska, and Pool 2 of the Mississippi River). MPCA prioritized deriving a PFOS WQC

because PFOS has the highest bioaccumulation potential in fish compared to the other PFAS with health-

based guidance values available. This high propensity of PFOS to accumulate in fish means that the

largest pathway of exposure for those interacting with PFOS-contaminated surface water is through

consuming fish caught in that waterbody. MPCA is in the process of developing WQC for other PFAS

found in surface waters in these impacted waterbodies.

The site-specific WQC for PFOS required an assessment of PFOS toxicity and exposure from fish tissue.

The criteria incorporate a model-based toxicological and exposure approach that is similar to that used

by the Minnesota Department of Health (MDH) to develop drinking water guidance. The criteria are

based on protecting the most vulnerable populations to PFOS toxicity, which are the developing fetuses

and newborn infants being exposed to PFOS through the placenta during pregnancy and through

breastmilk in early life. The new WQC for PFOS can be expressed either as a fish tissue concentration or

as a water concentration. For fish tissue, the WQC is 0.37 nanograms PFOS per gram (ng/g). The

corresponding WQC for water is 0.05 nanograms per liter (ng/L). The goal of these WQC is to reduce the

levels of PFOS in water so that freshwater fish consumption does not result in body burdens greater

than those associated with health effects.

Completed for PFOS, ongoing for other PFAS

Leader: MPCA Water Quality Standards Unit. Partners: MPCA Water Assessment and MDH Health

Environmental Surveillance and Assessment.

Benefits: PFOS WQC are based on protecting people’s health from the presence of this toxic

pollutant in Minnesota’s surface waters and fish. Reductions of PFOS have already been

documented in some surface waters due to national restrictions by EPA on some PFAS, including

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PFOS, and ongoing remediation activities. Any efforts to reduce PFOS pollution also benefit fish and

wildlife.

Challenges: The PFOS WQC consist of an applicable fish-tissue concentration and surface water

concentration. These values are very low and require the use of the most recently developed

analytical methods to assess. The MPCA has a contract with SGS AXYS Analytical, which recently

lowered reporting limits for PFOS and other PFAS. The fish-tissue WQC of 0.37 ng/g can be

accurately quantified by SGS AXYS, but the water concentration of 0.05 ng/L cannot. The MPCA’s

Effluent Limit Unit is working with the Environmental Data Quality Unit to develop guidance related

to these analytical issues.

Minnesota’s impaired waters or 303(d) list contains 10 existing impairments for PFAS. These include

impairments based on MDH’s fish consumption advice (an approach MPCA no longer uses for listing

waters that are impaired for consumption of fish tissue) and on exceedances of site-specific WQC.

There are a large number of new surface water and fish-tissue PFOS datasets available since the last

time PFAS was assessed statewide, and the new site-specific WQC is more stringent than prior

values. The MPCA is continuing to work on identifying the best path forward in assessing and listing

impaired waters for PFAS. MPCA is considering the long-term need for a statewide PFOS WQS,

which would result in statewide assessment for impaired waters listing wherever PFOS fish tissue

data were available.

Resources: The development of the PFOS WQC took an MPCA staff person approximately two years

and involved the support of several other technical staff at MPCA and MDH. This effort was possible

because MDH had already conducted a human health risk assessment for PFOS, containing a

reference dose and a serum model for understanding PFOS transfer to infants. Currently, the Water

Quality Standards Unit is developing new site-specific WQC for PFOA (which would allow for

additional updates to existing WQC for Bde Maka Ska and Pool 2), PFBA, PFHxS, and PFBS. These

PFAS also have MDH toxicological assessments and health based guidance for drinking water that

are relevant for this work. The development of the new interim fish consumption rate for women of

childbearing age took almost a year to obtain and review survey datasets; this rate needs further

review and consultation with Tribes and other subsistence fishing communities before adopting into

a statewide rule.

Required monitoring for PFAS at active landfills that land-apply leachate

Most active landfills dispose of leachate by sending it to WWTPs, but nine MSWs land-apply their

leachate at on-site fields or discharge it to a stormwater pond. In the past five years, MPCA has begun

incorporating PFAS monitoring requirements in the permits for these facilities. As of 2020, all facilities

land-applying leachate are required to monitor for PFAS in down-gradient groundwater wells and in

leachate. This data is reported to MPCA and included in annual reports. Intervention limits are ¼ the

lowest available HBV, HRL, RAA, or MCL. For PFAS, there are five intervention limits (PFOS = 3.75 ng/L,

PFOA = 8.75 ng/L, PFBS = 500 ng/L, PFHxS = 11.75 ng/L, and PFBA = 1750 ng/L). At least four facilities

have reported concentrations in down-gradient groundwater wells that exceed the intervention limit –

the concentrations in these wells also exceed the MDH guidance values. Next steps for management

plans are being considered. Options include tightening waste acceptance rules, installing treatment

systems, and taking actions to ensure that down-gradient drinking water receptors are not impacted by

PFAS plumes emanating from the facility. If down-gradient drinking water wells are found to have PFAS

contamination stemming from the facility, the facility would need to install and maintain a point of use

drinking water treatment system (such as GAC filter), as is done when PFAS contamination is found

through the down-gradient monitoring wells in the CLP.

Work status: ongoing

Leader: MPCA Solid Waste Permitting Section. Partners: Solid waste landfill operators.

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Benefits: Landfill Permittees have established an understanding that PFAS are a component of their

leachate and have become aware of the potential long-term impacts that the practice of land

applying leachate may have on the environment.

Challenges: There are no easy solutions for the problem of high PFAS levels in landfill leachate. PFAS

are especially persistent compounds – traditional methods to reduce the volume of leachate (like

evaporation) will not decrease the concentration of PFAS in the leachate; in fact, these approaches

will either concentrate PFAS in the leachate or diffuse the PFAS through the air in a way that may

cause widespread contamination. Treatment of leachate to remove PFAS is effective, but costly (as

seen in the DRP results from Kandiyohi County Landfill described in the section above). Reducing

PFAS sources to landfills moving forward (as described in the pollution prevention issue paper) will

be an important element to the overall PFAS management approach. Improvements to treatment

and destruction technology for PFAS over time will hopefully reduce the costs associated with

installing and maintaining PFAS treatment systems.

Resources: The permitted facilities are responsible for paying for PFAS monitoring. MPCA staff

oversee results.

Gaps and opportunities

There are several gaps remaining on issues related to PFAS waste, which can be categorized as gaps in

research or knowledge, gaps in state assistance, and gaps in regulation.

Research

One of the most significant gaps in knowledge when it comes to PFAS waste is related to the potential

risks posed by land-applying biosolids from WWTPs that may have elevated levels of bioaccumulative

and persistent PFAS like PFOS. Land-application of biosolids has many beneficial outcomes and

alternative disposal options for PFAS-containing biosolids also pose potential risks. The proposed

research project described below would help understand the relative risks of biosolids management

strategies so that land-application of biosolids can continue whenever it is responsible and feasible.

Another gap in PFAS research relates to PFAS groundwater plumes emanating from landfills currently

managed by MPCA’s closed landfill program. Initial investigation of down gradient groundwater at these

landfills indicated that PFAS levels exceeded health-based values in 55 locations – sometimes by a large

margin. Investigations into these PFAS plumes will help define the extent and movement of them so that

appropriate remedial actions can be taken to protect drinking water consumers and farmers whose

property may be impacted by PFAS pollution. Currently there are not funds available to conduct these

research projects. These opportunities are described in more detail below.

Conduct study of biosolids fate and transport following land-application

While land application of biosolids has benefits for farming, land application of contaminated biosolids is

a known source of PFAS to groundwater, soil, surface water, crops, and, in some

cases, livestock. There are many unknowns regarding how PFAS moves out of biosolids and into the

environment and food supplies. These gaps in knowledge about PFAS fate and transport make it

difficult to proactively manage biosolids without potentially causing groundwater or surface water

contamination. The goal of this study is to collect data that would inform tools used to evaluate PFAS

risks in land-applied biosolids and manage biosolids appropriately. Specifically, this project proposes to

1) evaluate and characterize PFAS concentrations in land‐applied biosolids; leaching from those

biosolids; and subsequent movement of PFAS into water and food; and 2) analyze alternative disposal

and treatment options and develop tools for managing PFAS‐contaminated waste streams. The study

would analyze 40 PFAS compounds and their breakdown products in biosolids, ash, landfill leachate,

compost, soil, water, and crops, to understand occurrence of PFAS in these mediums and allow

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characterization of the risk associated with land application. Total oxidizable precursor (TOP) analysis

would be performed to determine whether longer chain PFAS compounds that are present in these

wastes can break down to PFOS, PFOA, and other long-chain PFAS compounds of concern. Non‐targeted

analytical techniques would be used to identify the presence of additional PFAS compounds that cannot

be detected with available standard analytical methods. This project was recommended for funding

under the LCCMR process, but funding for all LCCMR projects was not secured for the entire 2020 set of

proposals. Nevertheless, a full description of the project, as proposed to LCCMR, is available online.

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This project is also discussed in the Limiting PFAS Exposure from Food Issue Paper.

Work status: proposed

Leader: MPCA Environmental Analysis and Outcomes Division. Partners: Participating wastewater

treatment plants and academic partners at University of Minnesota and Texas Tech University.

Benefits: This project will develop pollution prevention, treatment, and disposal options that can be

applied statewide. Data from field and lab-based leaching and uptake studies could be used to

develop screening values for biosolids. Long‐term implementation of these strategies will safeguard

drinking water and food supplies for current and future needs.

Challenges: Understanding the fate and transport of PFAS after land-application requires sampling

in multiple media, including surrounding surface water, porewater in soils, down-gradient

groundwater, crops planted on the biosolids amended fields, and the soil itself. Extra care must be

taken during application to avoid cross-contamination between controlled plots, including cleaning

of tractors and other equipment between and away from plots. Using the results of the Minnesota

study (and similar studies currently being undertaken by Wisconsin and Michigan) to develop a tool

to determine risk levels and application strategies for biosolids would require significant time and

effort.

Resources: This project proposal is complex, and would likely require about $1.4 million to complete

in full. However, some aspects of the project proposal could be completed as standalone projects

that require less funding.

Conduct additional investigations of PFAS groundwater plumes down-gradient of closed landfills

Prior monitoring of PFAS in groundwater down-gradient of landfills in the CLP has revealed that many

facilities, especially those that have historically accepted PFAS-rich waste from industrial facilities

including 3M, have very high levels of PFAS in groundwater. Though there has been some work

conducted to test drinking water wells in residencies that may be impacted, the extent of these PFAS

plumes is not yet well understood. Many PFAS are highly mobile in groundwater and could have moved

far from the original closed landfill location. Additional funding would allow the CLP to conduct

additional groundwater investigations surrounding the facilities with the highest PFAS groundwater

concentrations.

Work status: proposed, funding required

Leaders: MPCA Closed Landfill Program.

Benefits: Existing work has confirmed that PFAS levels in groundwater surrounding some unlined

closed landfills far exceed health-based concentrations established by MDH. Additional investigation

will ensure that MPCA is supplying treatment or other remedial actions to any impacted private or

public drinking water systems. This effort would also allow MPCA to monitor for other contaminants

of concern, like 1,4-dioxane, that may be co-occurring at the same sites. Finally, some closed

landfills are present in parts of the state used for agriculture. Identifying and stemming PFAS plumes

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Legislative-Citizen Commission on Minnesota Resources. (2020). 2020 Environment and Natural Resources Trust Fund

Recommendations. Retrieved from: https://www.lccmr.leg.mn/projects/2020/2020_recommendations_by_subdivision.html

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in these agricultural regions would help prevent or remediate contamination of farmland that could

lead to uptake of PFAS into crops or livestock.

Challenges: The CLP has a limited number of staff available to complete PFAS investigations. Hiring a

consultant would increase project costs, but would allow CLP to complete more investigations in a

shorter amount of time. Understanding the extent of PFAS plumes may require digging additional

temporary or permanent monitoring wells, which can be costly.

Resources: The costs of these investigations would depend on if contractors were required to lead

investigations and install new monitoring wells and the number of closed landfills with PFAS

concentrations in groundwater that would warrant further investigation. The Closed Landfill

Investment Fund could be used to entirely or partially fund these investigations. Drilling wells and

sampling could occur in one season.

Assistance

Additional improvements in PFAS management of waste could come from increased guidance and non-

regulatory assistance. There are opportunities to investigate and identify PFAS-containing inputs to

multiple types of waste streams. Better identification and efforts in this area would help waste

treatment facilities understand which PFAS sources are driving the levels of PFAS seen in their end

products like biosolids, effluent and leachate. Trying to identify PFAS-containing inputs to waste facilities

involves two related but distinct efforts. One is PFAS pollution prevention. As described in the issue

paper on pollution prevention, current chemical regulation practices in the US allow many PFAS to be

used in industry and commerce without consideration of how those uses may impact waste facilities

once the materials are disposed of. Widespread use of PFAS in products and lack information about

PFAS content in products make it difficult, if not impossible, for consumers and businesses to entirely

avoid PFAS. More regulation of PFAS-containing products is needed so that the burden of researching

and identifying PFAS-containing products does not fall on businesses and individuals. The second type of

effort involves identifying the most significant PFAS inputs to the waste facility, which are often

industrial in origin, and take action to reduce those inputs. This paper addresses primarily the second

area of work. Currently, there is not a robust industrial pretreatment program for PFAS at WWTPs.

MPCA could support WWTPs in identifying upstream sources and requiring source reduction strategies

from significant contributors of PFAS.

One known significant source of PFAS to waste facilities is PFAS-containing firefighting foam and the

PFAS-enriched wastewater produced when these foams are used. Many facilities are storing PFAS-

containing firefighting foam that is now illegal to use for testing and training purposes.

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These facilities

would like to dispose of the foams but are lacking information on how to do so responsibly. MPCA is

developing guidance on this topic and could also develop guidance on the topic of how to manage

disposal of PFAS-containing runoff collected after these foams are used in an emergency. More detail on

opportunities for increased assistance and guidance are described below.

Issue guidance on the collection and disposal of PFAS-containing firefighting foam concentrate and

wastewater

Releases of PFAS-containing firefighting foam (sometimes called aqueous film-forming foam, or AFFF)

are known to be major sources of PFAS to the environment. In 2020, Minnesota banned the use of PFAS-

containing firefighting foams for testing and training purposes. Additionally, MPCA has conducted

outreach with relevant stakeholders to encourage the use of PFAS-free foams in the event of an

emergency. Due to the added restrictions on using PFAS-containing firefighting foams and the increased

knowledge about the potential risks these firefighting foams pose to human health, many entities

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MPCA. (n.d.). PFAS in firefighting foam. Retrieved from: https://www.pca.state.mn.us/waste/pfas-firefighting-foam

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(including municipal firefighting agencies) are looking to dispose of their stocks of unused PFAS-

containing firefighting foam concentrate. MPCA is currently developing a guidance document to help

these groups understand the available options for disposal.

The new regulations in Minnesota on the use of PFAS-containing firefighting foam have also created

some uncertainty about how spent PFAS-containing firefighting foams can be captured and disposed of

after they are used in an emergency. Developing guidance for this scenario is more challenging because

in an emergency setting, the PFAS containing firefighting foams are mixed with water and could be

applied to a relatively large area that could not easily facilitate collection of the contaminated water

after the fire has been extinguished. If contaminated water is able to be collected, there are several

options available for treating or disposing of it including filtration, precipitation agents, and foam

fractionation. MPCA could consider developing a guidance document to help inform groups that use

Class B firefighting foams about options available for disposing of PFAS-containing water associated with

firefighting and considerations for collected firefighting wastewater.

Work status: ongoing

Leader: MPCA, Industrial Division and Resource Management and Assistance Division.

Benefits: Encouraging responsible disposal of PFAS-containing firefighting foams and PFAS-

containing wastewater associated with firefighting events will result in less PFAS discharged to the

environment, which has the direct benefit of reducing exposures for humans and wildlife.

Developing guidance also ensures that MPCA provides consistent and clear advice.

Challenges: PFAS is not currently listed as hazardous waste under RCRA, which means that there are

generally not regulations of the handling, transport, and disposal of products like PFAS-containing

firefighting foams. Though PFAS could be considered hazardous substances under MERLA, and

parties could be held liable if they release PFAS to the environment at levels impacting human

health and the environment, there are not clear waste management and disposal requirements

related to these materials. This complicated regulatory status of PFAS can make communicating with

stakeholders difficult.

Resources: Guidance documents require time of staff to write and review materials.

Engage with WWTPs to identify industrial PFAS sources and opportunities for source reduction

The goal of this project would be to focus on source reduction of PFAS waste streams entering municipal

WWTPs. PFAS can be in both industrial and domestic waste streams that are contributing influent to the

facility. Certain types of waste streams, particularly certain types of industrial waste streams, are known

to often be high in PFAS. The Municipal Wastewater Program would assist and educate WWTPs on

identifying PFAS inputs to their facilities and developing source reduction strategies, which WWTPs can

use to develop and implement source reduction plans specific to their WWTP. Education materials could

include recorded seminars, fact sheets, and other communication materials to help discuss PFAS with

WWTPs and operators of industrial facilities that discharge to WWTPs. This work would be modeled off

of the successful effort by Michigan’s Department of Environment, Great Lakes, and Energy (EGLE) to

monitor effluent at WWTP, identify industrially-impacted WWTPs, and implement industrial pre-

treatment plans for PFAS.

Work status: under consideration

Leader: Municipal Wastewater Program. Partners: Municipal Wastewater Treatment Facilities and

Industries.

Benefits: Focusing on source reduction as a major part of managing PFAS at WWTP will reduce the

amount of PFAS entering the WWTPs, which in turn results in reduced PFAS in both the effluent and

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biosolids. This approach also helps ensure that the industrial entities generating the pollution are

contributing to the costs associated with managing PFAS, and not passing these costs forward to

WWTPs, which are taxpayer and user-funded facilities.

Challenges: Though EGLE’s work on identifying PFAS sources to WWTPs helped identify the major

common industrial sources to target for pollution reduction, there is a lack of information about

some of the smaller sources of PFAS. In some cases, industries or individuals (or perhaps even the

municipal WWTP itself) could be using PFAS-containing products without knowing it, especially

because many PFAS-containing products do not have labels indicating that the product contains

PFAS. This can make it challenging to determine what exactly is contributing to the levels of PFAS

seen at wastewater plant. Another challenge will be to develop a cooperative and collaborative

effort with the wastewater community. Although several groups representing cities and municipal

WWTPs have indicated interest in a project like this one, it can be difficult for MPCA to enter as a

trusted party due to its regulatory authority. Some WWTPs may be hesitant to participate in a PFAS

study or do voluntary PFAS sampling, out of a concern that that might lead them to be regulated

sooner.

Resources: Additional staff time or additional staff will be needed to help communicate, educate,

develop resources, and oversee implementation of the plans for WWTPs. The MPCA has a limited

number of staff with the knowledge to assist in this effort, and they currently have a full plate with

their core work. Successful completion of this effort would require additional staff time from key

subject matter experts, or potentially an outside contract. Funding to assist WWTPs with the cost of

sampling could encourage higher rates of participation.

Regulation

There are many gaps when it comes to regulating waste containing PFAS. The goal of regulation is to

ensure that harmful levels of contaminants do not reach the environment. Different waste facilities fall

under different regulatory programs, and the “first step” in a process to begin mandating assessment

and reductions in PFAS releases through permit conditions would be different as well.

Facilities that discharge effluent or wastewater to surface water have NPDES permits, which operate on

a five-year renewal cycle. Generally speaking, permitting authorities first develop a water quality

standard and then modify NPDES permits to require monitoring for the relevant pollutant (this could

also happen in a specific geographic area using a site-specific water quality criteria). After reviewing the

monitoring data, effluent limits may be included in the following permit cycle where facilities

demonstrated a reasonable potential to cause or contribute to an exceedance of the standard. Having

data on existing levels in WWTP discharges in advance of a water quality standard helps the regulatory

agency develop reasonable and robust implementation procedures concurrently with the standard such

that permit holders understand options they may have in advance of permit issuances. These options

may include technical assistance and enhanced pretreatment work to identify and minimize sources

such that when the water quality standard becomes available effluent levels may have decreased to the

point that a limit is not required.

The process for instigating pollution reduction actions in landfills is different than that used for NPDES-

permitted wastewater facilities. At landfills, generally MPCA would first require monitoring for the

pollutant in groundwater. Then, if groundwater concentrations exceed intervention limits, a process

would ensue to reduce releases and take remedial action, if needed. These differences in regulatory

structures between solid waste and wastewater mean that the process of regulating PFAS is various

waste facilities will follow a different of steps. Opportunities to begin these processes under the CWA

and solid waste programs are described below.

Minnesota’s PFAS Blueprint • February 2021

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Require monitoring for PFAS in NPDES permitted facilities

Facilities that discharge effluent or wastewater to surface water do so under conditions set in NPDES

permits, which have a five-year permit term. Some states, such as Michigan and Alabama, have required

some facilities to monitor and report the levels of PFAS in their effluent. These states’ strategies to

require effluent monitoring generally focus on those facilities that are most likely to have PFAS – either

because they are industries that use PFAS or they receive wastewater from such industries. The EPA has

also recently announced an interim strategy to address PFAS through certain EPA-issued wastewater

permits, despite the fact that there are no federal surface water standards for PFAS.

186

The EPA strategy

recommends a phase-in of effluent monitoring at facilities where PFAS is likely to be present, with the

phase-in based on the availability of EPA-approved analytical methods. MPCA could develop a similar

strategy to incorporate PFAS monitoring requirements into some or all NPDES permits. Developing and

implementing the strategy would require considering which facility should monitor, frequency of

monitoring and number of samples, specific PFAS compounds monitored, location of sampling (influent,

effluent, both), and appropriate permit conditions.

Leader: MPCA Analysis and Outcomes Division.

Benefits: Understanding sources of PFAS (such as PFAS producing facilities and other industrial

facilities that use PFAS-containing products) and levels of PFAS released conduits like WWTPs would

help guide future strategic PFAS reduction strategies, including ways to reduce PFAS releases from

the most meaningful sources. Effluent monitoring data would help support development of

implementation procedures for any future water quality standard. This monitoring data could also

be used to support future regulations of PFAS uses or restrictions on PFAS handling and disposal.

Challenges: PFAS sampling is costly. Prioritizing which permits have monitoring requirements

included or updated will require analysis of existing PFAS effluent data from Minnesota and other

states.

Resources: MPCA would not require significant resources to complete this action.

Develop statewide CWA Water Quality Standards for PFAS

Preliminary data from monitoring PFAS in fish indicate that several PFAS – and particularly PFOS -

bioaccumulate in fish tissue at levels that are a concern for human consumption and potentially the

health of the aquatic ecosystem. Implementing statewide Water Quality Standards (WQS) for

bioaccumulative PFAS would provide a regulatory basis for reducing PFAS loading to aquatic ecosystems,

thereby removing the need for fish consumption guidance or other restrictions on the beneficial uses of

waterbodies in the state. A statewide WQS for PFOS or other PFAS would trigger the regular regulatory

process for consideration of monitoring requirements and/or effluent limits for facilities that have

permits to discharge to Minnesota waters. MPCA would also need to develop a path forward to assess,

list, and address PFOS or other PFAS impairments.

Every three years, the CWA mandates that MPCA review existing WQS and propose revisions or

additions as needed. The MPCA’s Water Quality Standards Unit is currently undertaking the Triennial

Standards Review process to determine MPCA’s 2021 – 2024 WQS work plan. The MPCA will be asking

for input on the need for additional PFAS water quality standards. If MPCA determines there is a need to

develop new PFAS WQS for any beneficial uses (drinking water, aquatic consumption, etc.), the

development of these numeric standards and adopting them into rule would be a multi-year process

with several steps including economic analysis, outreach to partners like tribes, outreach to potentially

impacted stakeholders, public comment steps (stipulated by the Administrative Procedures Act), and

186

EPA. (2020, Nov. 30

). New Interim Strategy to Address PFAS through certain EPA-issued wastewater permits. [News

release]. Retrieved from: https://www.epa.gov/newsreleases/new-interim-strategy-will-address-pfas-through-certain-epa-

issued-wastewater-permits

Minnesota’s PFAS Blueprint • February 2021

170

finally EPA approval. If the EPA does not publish recommended CWA criteria for PFAS and MPCA needs

to develop standards itself, the standards will also require external peer review, which adds additional

time and review to the process.

Work status: under consideration

Leader: MPCA Water Quality Standards Unit. Partners: MPCA Water Assessment and MDH Health,

Environmental Surveillance, and Assessment Section.

Benefits: Water Quality Standards are regulatory values that are important tools to prevent and

abate toxic pollutants affecting the beneficial uses of water resources. PFOS and other PFAS are

pollutants known to occur in Minnesota surface waters. Their presence results from many ongoing

water discharges and air emissions from both sources and conduits of PFAS. The levels of PFAS in

some of Minnesota’s waterbodies are causing some municipalities to install treatment of drinking

water for PFAS, at great expense to taxpayers. Levels of PFAS are also impacting fish, triggering the

need for fish consumption guidance, up to and including “do not eat” for fish at popular fishing

locations. Minnesota DNR is currently investigating potential uptake of PFAS from surface water to

game people eat, like deer. These damages to natural resources hurt all Minnesotans, but especially

those who rely on locally caught fish and game as a healthy source of protein for themselves and

their families. Statewide WQS would provide transparent regulatory values and allow for the

implementation of all related water quality programs – including effluent limits, assessment and

impaired waters listings, and options to address resulting impairments. These related actions would

reduce ongoing PFAS releases to the environment and support continued progress on reducing the

presence and concentration of these toxic pollutants in already impacted regions.

Challenges: WQS rulemaking involves significant agency staff resources. The benefits and costs of

implementing WQS into statewide permitting and impaired waters listing would need to be

evaluated. Rulemaking for PFAS WQS are especially complex because PFAS is a family of compounds

consisting of thousands of known structures. Given the current state of knowledge regarding PFAS

toxicity, MPCA would likely only be able to adopt WQS for human health based beneficial uses

(drinking water and aquatic consumption) for those PFAS with health assessments completed.

Additionally, research into appropriate fish consumption rates would be needed, including outreach

to high fish consuming communities. Considerations of fish-eating wildlife and water to terrestrial

organism impacts (like deer-drinking contaminated surface water) could also be considered. This

effort would require a team of staff scientists and program managers with various areas of

expertise.

Considering how WQS for PFAS would impact facilities like landfills, WWTPs, and composters would

be important. These WQS could impact how landfill leachate, biosolids, and other waste products

are managed. When considering options for implementation, significant input from partners and

stakeholders would be needed.

Resources: Adopting WQS requires support from the Governor’s Office and other state agencies, in

addition to time dedicated by many MPCA staff including a Rule Coordinator and Legal Unit support.

Develop rules stablishing requirements for PFAS handling, storage, and disposal requirements

The unregulated disposal of PFAS waste from chemical producers, metal platers, tanneries, and many

other industrial activities around the country have resulted in discharges to air and surface water that

caused dangerous exposures for humans and wildlife. Unregulated handling of these persistent and

mobile PFAS can result in PFAS and their toxic combustion products to spread to a wide geographic

region. In many cases, these releases have resulted in expensive remediation efforts to treat drinking

water, surface water, and soil. In Minnesota, improper disposal of PFAS from 3M resulted groundwater

contamination that impacted at least 150 square miles. The relative lack of PFAS disposal regulations in

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the United States compared to Europe has resulted in instances of chemical companies importing PFAS

waste from Europe to the US, where it is relatively cheap and easy to dispose of PFAS. Though there

were two petitions to EPA (from 2019 and 2020) requesting the EPA regulate PFAS as hazardous wastes

subject to the management and disposal requirements of Subtitle C of RCRA, EPA has taken no action on

these petitions.

187

Subsection C of RCRA includes management and disposal requirements for substances considered

“hazardous wastes.” The objective of the Subtitle C program is to ensure that these wastes are handled

in a manner that protects human health and the environment. To this end, there are Subtitle C

regulations for the generation, transportation, treatment, storage, or disposal of hazardous waste. As an

authorized program, the MPCA implements RCRA through Minnesota’s Hazardous Waste Rules. PFAS

are not currently explicitly listed as hazardous wastes under the Minnesota’s Hazardous Waste Rules,

which means that only some PFAS-containing wastes with extremely high concentrations are currently

regulated for disposal in Minnesota.

MPCA could conduct rulemaking that would define PFAS as “hazardous wastes” under Minnesota’s

Hazardous Waste Rules. This process is complex, and would first require establishing which PFAS-

containing waste should be considered hazardous waste by setting threshold concentrations that

delineate high enough risk to support the imposition of hazardous waste requirements – either for

specific PFAS or the PFAS class as whole. Appropriate handling and disposal requirements would also

need to be developed. In defining PFAS as hazardous wastes, MPCA could enforce requirements related

to storage, handling, and disposal of these materials.

Work status: under consideration

Leader: MPCA Industrial Division, Hazardous Waste Program.

Benefits: Defining some PFAS-containing materials as hazardous waste and establishing storage,

transport, handling and disposal requirements would result in fewer environmental releases of PFAS

and reduced human exposures. The effort will likely also raise awareness about the dangers of PFAS-

containing products and encourage investments in safer alternatives.

Challenges: There are thousands of PFAS in use today, many of which are unknown to the public

due to their status as “confidential business information.” Because PFAS are so persistent in the

environment and ubiquitous in consumer products and industrial processes, there are detectable

levels of PFAS in many common waste products. Some products contain PFAS despite not having any

PFAS intentionally added. Determining which PFAS-containing materials should be included as

hazardous wastes in a rulemaking would require research and significant consideration. Destruction

and disposal of PFAS is expensive and difficult, and much remains to be known about which

destruction or disposal options will result in the least amount of environmental harm.

Resources: Rulemaking is a time-consuming effort that requires staff resources for several years.

Require monitoring for PFAS in groundwater at active landfills

Prior monitoring of leachate, groundwater, and landfill gas at solid waste facilities including municipal,

industrial, and construction and demolition landfills indicated that PFAS levels in all of those media can

be high. Many construction and demolition landfills are unlined. MPCA could consider adding PFAS to

the list of analytes with mandatory groundwater monitoring for the duration of the landfills’ active life

and post-closure care period. This would allow MPCA to determine when intervention limits for PFAS

are exceeded and management actions at the landfill should be considered. This effort would also

187

EPA. (n.d.). Petitions to the Office of Land and Emergency Management. Retrieved from:

https://www.epa.gov/petitions/petitions-office-land-and-emergency-management

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172

provide valuable groundwater data that could help inform drinking water or surface water monitoring at

sites that may be impacted.

Work status: under consideration

Leaders: MPCA Resource Management and Assistance Division.

Benefits: Additional monitoring of PFAS in groundwater surrounding municipal landfills, industrial

landfills, and construction and demolition landfills would inform MPCA, MDH, and landfill operators

when PFAS releases could result in hazardous exposure to humans or wildlife. That would allow

these agencies to proactively protect human health and the environment by requiring appropriate

intervention strategies.

Challenges: PFAS analysis is expensive, running about $300-400 per sample. Many landfills would be

hesitant to conduct ongoing PFAS monitoring, especially if management strategies to reduce PFAS

releases or PFAS loading into the landfill continue to be ill-defined.

Resources: Landfills would be responsible for the cost of monitoring. Staff time would be needed to

design and oversee the new monitoring.

Overview of intersectional issues

 Pollution prevention: Reducing PFAS pollution at the source places the burden

with the polluters rather than conduits that do not use PFAS themselves, like landfills, WWTPs,

and composting facilities. PFAS labeling could help inform landfills, WWTPs, and composting

facilities about which products or upstream facilities may be sources of PFAS. See the Preventing

PFAS Pollution Issue Paper for actions related to reducing the overall production and emission of

PFAS products.

 Quantifying PFAS toxicity: Understanding the potential health impacts of PFAS exposure is key

in ensuring exposure stays below “safe” thresholds and communicating with the public. Health-

based guidance values, however, require data on toxicity and exposure that are not available for

the vast majority of all the PFAS compounds found in the environment. See the Quantifying

PFAS Risks to Human Health Issue Paper for more information on challenges stemming from

PFAS toxicity data limitations. 

 Developing and expanding access to analytical methods: Analytical methods for PFAS are

expensive and time-intensive to run and include only a subset of all PFAS that may be occurring

in waste facilities like landfills, composting facilities, and WWTPs. Increased access to non-

targeted analysis and other screening-level PFAS methods would be beneficial identifying

sources of PFAS to waste facilities – see the Measuring PFAS Effectively and Consistently Issue

Paper for more information on the costs and challenges associated with measuring PFAS in

various matrices. 

 Understanding risks from PFAS air emissions: PFAS can be released to the air from volatilization

in landfills or from waste incineration. It is currently unknown if levels of PFAS in air around

these waste facilities could be associated with adverse health effects. It is also unknown if PFAS

emissions to air through waste incineration results in contamination of surrounding surface

water and soils. See the Understanding Risks from PFAS Air Emissions Issue Paper for more

information.

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173

Appendix A. List of gap-filling opportunities identified in all issue papers

Table A-1. All gap-filling initiatives described in issue papers.

Opportunity

Action type

Authority

Resources needed

Timeline

Contingencies

Require labeling of

PFAS-containing

products

P2; Regulation

New legislative

grant

New funding

(appropriation)

Medium to Long-

term

Legislative action (state or federal) needed for

labeling and disclosure requirements. Policy

research could be completed by MPCA. There are

no known federal actions pending on this subject.

Regulate PFAS using a

framework of essential,

substitutable, and non-

essential uses

Pollution Prevention

(P2)

New legislative

grant

New funding

(appropriation)

Medium to Long-

term

Labeling and disclosure requirements would

greatly improve the efficiency of this action

(without them, significant research and

investigation is needed to determine if a product

contains PFAS). Level of funding required would

depend on the scale and scope.

Limit or ban PFAS in

known non-essential

uses

P2; Regulation

New legislative

grant

New funding

(appropriation)

Medium to Long-

term

Legislative action (state or federal) would be

needed.

Develop public sector

purchasing guidelines

to end purchases of

PFAS-containing

products

Pollution Prevention

(P2)

Agency existing

Existing funding

Medium to Long-

term

Labeling and disclosure requirements would

greatly improve the efficiency of this action

(without them, significant research and

investigation is needed to determine if a product

contains PFAS). Essential uses of PFAS would need

to be determined. Added funding could accelerate

timelines.

Consider providing

financial and technical

assistance to

businesses for

switching from PFAS-

containing products

P2; Guidance/

Assistance

Agency existing

Existing + Added

funding

Medium to Long-

term

Funding would be needed in some programs if

financial assistance were to be extended to

businesses for this purpose. Labeling and

disclosure of PFAS products would improve the

efficiency of this action (without them, significant

research and investigation is needed to determine

if a product contains PFAS).

Ensure capacity to

meet demand for non-

targeted PFAS

analytical approaches

Research and

Development (R&D)

Agency existing

Added funding

(appropriation)

Medium to Long-

term

Staff and funding would be needed to expand PHL

analytical capacity for PFAS. Alternative funding

streams (such as federal grants) could be explored

to acquire instrumentation or for other purposes.

Minnesota’s PFAS Blueprint • February 2021

174

Opportunity

Action type

Authority

Resources needed

Timeline

Contingencies

Ensure capacity to

meet demand for

alternative PFAS

methods

Research and

Development (R&D)

Agency existing

Added funding

(appropriation)

Medium to Long-

term

Staff and funding would be needed to expand PHL

analytical capacity for PFAS. EPA plans to publish

total PFAS methods in 2021. Alternative funding

streams (such as federal grants) could be explored

to acquire instrumentation or for other purposes.

Compile information

on inhalation PFAS

toxicity

Guidance/Assistance

Agency existing

Existing funding

Short-term

None.

Research cutting-edge

risk assessment

techniques for data-

poor PFAS

Research and

Development (R&D)

Agency existing

Existing funding

Short-term

Currently collaborating with EPA ORD on this

topic.

Develop an

epidemiological study

of residents exposed to

PFAS through drinking

water

Research and

Development (R&D)

New legislative

grant

New funding

(appropriation)

Medium to Long-

term

This effort would require significant funding.

ATSDR is conducting ongoing biomonitoring

studies at multiple sites in the US. Minnesota

applied for the East Metro to be included in this

effort, but was not selected.

Conduct drinking water

monitoring under the

Fifth Unregulated

Contaminant

Monitoring Rule

(UCMR5) (2023-2025)

Monitoring;

Regulation

Agency existing

Existing funding

Medium to Long-

term

None.

Conduct routine PFAS

monitoring in fish

Monitoring

Agency existing

Added funding

(appropriation)

2021 Legislative

proposal

Funding would be needed to include PFAS in

regular ongoing monitoring plans.

Develop statewide

water quality standards

for PFAS - Class 1

drinking water

Regulation

Agency existing

Existing funding

Short-term

None.

Minnesota’s PFAS Blueprint • February 2021

175

Opportunity

Action type

Authority

Resources needed

Timeline

Contingencies

Consider developing

statewide water

quality standards for

PFAS - Class 2 aquatic

consumption, aquatic

life

Regulation

Agency existing

Existing funding

Medium to Long-

term

EPA is scoping the development of recommended

CWA aquatic life and human health criteria for

PFAS. MPCA would consider adopting federal

criteria when they are published.

Inform and engage

with farmers about

potential upstream

sources of PFAS

Guidance/Assistance

Agency existing

New funding

(appropriation)

Medium to Long-

term

Funding would be needed to support sampling of

potential upstream sources.

Consider developing a

new rule to make air

toxics reporting

mandatory, including

PFAS

Regulation

Agency existing

Existing funding

Medium to Long-

term

None.

Explore cross-program

air modeling project to

understand PFAS air

emissions and their

impacts on air,

groundwater, surface

water, and fish tissue

Research and

Development (R&D)

Agency existing

Existing funding

Medium to Long-

term

Models to estimate groundwater leaching values

would be relevant to this effort -- EPA is working

with some states to develop soil to groundwater

transfer models for PFAS. Other states in the Upper

Midwest are also conducting PFAS soil and biosolids

studies that would be used to inform similar

modeling. Developing soil-to-groundwater leaching

values is also listed as an opportunity for action in

Minnesota.

Develop Aquatic

Toxicity Profiles for

PFAS to assess the

need to update aquatic

life criteria or develop

statewide aquatic life

standards

Research and

Development (R&D)

Agency existing

Existing funding

Medium to Long-

term

None.

Develop state-wide

wildlife risk values for

PFAS, leveraging data

from existing studies

Guidance/Assistance

Agency existing

Existing funding

Medium to Long-

term

None.

Minnesota’s PFAS Blueprint • February 2021

176

Opportunity

Action type

Authority

Resources needed

Timeline

Contingencies

Assess the need for

acute wildlife risk

assessment from

exposure to PFAS-

containing foam

Guidance/Assistance

Agency existing

Existing funding

Medium to Long-

term

None.

Formally define PFAS as

hazardous substances

under MERLA

Regulation

New legislative

grant

Existing funding

2021 Legislative

proposal

Would require legislative action. On the federal

level, EPA could finalize proposed rulemaking to list

PFOA and PFOS as hazardous substances under

CERCLA. Federal legislation has also been proposed

to designate all PFAS as hazardous substances under

CERCLA.

Establish authority for

MPCA to request data

regarding

contaminants of

potential

environmental concern

R&D; Regulation

New legislative

grant

Existing funding

2021 Legislative

proposal

None.

Develop soil to

groundwater leaching

values for PFAS to be

used in clean-ups and

disposal guidance

Guidance/Assistance

Agency existing

Existing funding

Medium to Long-

term

EPA is working with some states to develop soil to

groundwater transfer models for PFAS. Many states

are conducting research to support similar values.

Update guidance for

recommended analyte

sampling at clean-up

sites to include PFAS

Monitoring;

Guidance/Assistance

Agency existing

Existing funding

Short-term

None.

Explore opportunities

to supplement the

state Remediation

Fund to support site

clean-ups

Guidance/Assistance

Agency existing

Added funding

(appropriation)

Medium to Long-

term

CERCLA hazardous substance listing for PFAS would

increase access to federal funds for cleaning up

PFAS-contaminated sites.

Conduct study of

biosolids fate and

transport following

land-application

Research and

Development (R&D)

Agency existing

New funding

(appropriation)

2021 Legislative

proposal

EPA is working with some states to develop soil to

groundwater transfer models for PFAS. EPA is also

developing a biosolids risk assessment for PFOA and

PFOS, which would include models of PFAS fate and

transport after land application of biosolids.

Minnesota’s PFAS Blueprint • February 2021

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Opportunity

Action type

Authority

Resources needed

Timeline

Contingencies

Conduct additional

investigations of PFAS

groundwater plumes

down-gradient of

closed landfills

Monitoring

Agency existing

Added funding

(appropriation)

2021 Legislative

proposal

Access to the Closed Landfill Investment Fund would

be needed to conduct these investigations.

Issue guidance on the

collection and disposal

of PFAS-containing

firefighting foam

concentrate and

wastewater

P2;

Guidance/Assistance

Agency existing

Existing funding

Short-term

EPA issued an interim PFAS disposal guidance

document, but this document contains no

information about concentration thresholds of PFAS

in waste that would be considered hazardous or

recommended disposal options based on those

thresholds. EPA plans to update this "guidance"

within three years.

Engage with WWTPs to

identify industrial PFAS

sources and

opportunities for

pretreatment

P2;

Guidance/Assistance

Agency existing

Added funding

(appropriation)

2021 Legislative

proposal

Non-targeted monitoring would increase the

understanding of which PFAS are present (including

any new PFAS for which there are currently not

analytical methods).

Develop hazardous

waste rules

establishing

requirements for PFAS

handling, storage, and

disposal

Regulation

Agency existing

Existing funding

Medium to Long-

term

Determination of concentration thresholds for PFAS

in waste that would warrant various requirements

on transport, management, and disposal is needed.

There are no known federal actions on RCRA

rulemaking -- various groups have petitioned EPA to

conduct rulemaking on PFAS disposal, transport,

and handling.

Develop a plan for

monitoring PFAS in

groundwater at active

landfills

Monitoring;

Regulation

Agency existing

Existing funding

Short-term

Traditional analytical methods for PFAS are

available, but some non-targeted monitoring would

increase the understanding of which PFAS are

present (including those for which there are

currently not analytical methods).

Develop a plan for

monitoring PFAS at

NPDES permitted

facilities

Monitoring;

Regulation

Agency existing

Existing funding

Short-term

Traditional analytical methods for PFAS are

available, but some non-targeted monitoring would

increase the understanding about which PFAS are

present (including those for which there are

currently not analytical methods).

Minnesota’s PFAS Blueprint • February 2021

178

Opportunity

Action type

Authority

Resources needed

Timeline

Contingencies

Evaluate options for

managing risks from

federally unregulated

contaminants in

drinking water

Regulation

Agency existing

Existing funding

Medium to Long-

term

Federal rulemaking for PFAS is currently

underway. Implementation of a federal drinking

water rule for PFAS would likely not begin until

2025.

Develop a plan for

performance testing

for PFAS at permitted

air sources

Regulation

Agency existing

Existing funding

Short-term

Performance tests have been limited; EPA is

working on approved performance test methods.

Accelerate existing

PFAS Pilot Inventory

Monitoring

Agency existing

Added funding

(appropriation)

2021 Legislative

proposal

None.

Table A-2. Gap-filling initiatives organized by timeframe.

2021 legislative proposal

Conduct additional investigations of PFAS groundwater plumes down-gradient of closed landfills

Conduct routine PFAS monitoring in fish

Engage with WWTPs to identify industrial PFAS sources and opportunities for pretreatment

Establish authority for MPCA to request data regarding contaminants of potential environmental concern

Conduct study of biosolids fate and transport following land-application

Formally define PFAS as hazardous substances under MERLA

Accelerate existing PFAS Pilot Inventory

Short-term

Compile information on inhalation PFAS toxicity

Issue guidance on the collection and disposal of PFAS-containing firefighting foam concentrate and wastewater

Research cutting-edge risk assessment techniques for data-poor PFAS

Update guidance for recommended analyte sampling at clean-up sites to include PFAS

Develop statewide water quality standards for PFAS - Class 1 drinking water

Develop a plan for monitoring PFAS in groundwater at active landfills

Develop a plan for monitoring PFAS at NPDES permitted facilities

Develop a plan for performance testing for PFAS at permitted air sources

Minnesota’s PFAS Blueprint • February 2021

179

Medium to long-term

Consider developing new rule to make air toxics reporting mandatory, including PFAS

Assess the need for acute wildlife risk assessment from exposure to PFAS-containing foam

Consider providing financial and technical assistance to businesses for switching from PFAS-containing products

Develop soil to groundwater leaching values for PFAS to be used in clean-ups and disposal guidance

Explore cross-program air modeling project to understand PFAS air emissions and their impacts on air, groundwater, surface water, and fish tissue

Require labeling of PFAS-containing products

Develop public sector purchasing guidelines to end purchases of PFAS-containing products

Develop an epidemiological study of residents exposed to PFAS through drinking water

Conduct drinking water monitoring under the Fifth Unregulated Contaminant Monitoring Rule (UCMR5) (2023-2025)

Inform and engage with farmers about potential upstream sources of PFAS

Develop aquatic toxicity profiles for PFAS to assess the need to update aquatic life criteria or develop statewide aquatic life standards

Develop state-wide wildlife risk values for PFAS, leveraging data from existing studies

Evaluate options for managing risks from federally unregulated contaminants in drinking water

Regulate PFAS using a framework of essential, substitutable, and non-essential uses

Ensure capacity to meet demand for non-targeted PFAS analytical approaches

Ensure capacity to meet demand for alternative PFAS methods

Explore opportunities to supplement the state Remediation Fund to support site clean-ups

Limit or ban PFAS in known non-essential uses

Consider developing statewide water quality standards for PFAS - Class 2 aquatic consumption, aquatic life

Minnesota’s PFAS Blueprint • February 2021

180

Appendix B. List of Minnesota PFAS values and selected other PFAS risk values

PFAS

Media

Description

Value

Units

Source

Notes

PFBA

groundwater

intervention limits (solid waste)

1750

ng/L

Minnesota

PFBA

groundwater/drinking

water

HRL (chronic)

7000

ng/L

Minnesota

PFBA

soil

SRV (incidental ingestion,

residential/recreational)

38000

ng/g

Minnesota

PFBA

soil

SRV (incidental ingestion,

commercial/industrial)

520000

ng/g

Minnesota

PFBS

sludge

screening level

1900

ng/g

Maine

PFBS

groundwater

intervention limits (solid waste)

500

ng/L

Minnesota

PFBS

groundwater/drinking

water

HRL (chronic)

7000

ng/L

Minnesota

PFBS

groundwater/drinking

water

HBV (chronic)

2000

ng/L

Minnesota

PFBS

soil

SRV (incidental ingestion,

residential/recreational)

57000

ng/g

Minnesota

PFBS

soil

SRV (incidental ingestion,

commercial/industrial)

77000

ng/g

Minnesota

PFHxS

groundwater

intervention limit (solid waste)

11.75

ng/L

Minnesota

PFHxS

groundwater/ drinking

water

HBV (chronic)

ng/L

Minnesota

PFHxS

soil

SRV (incidental ingestion,

residential/recreational)

130

ng/g

Minnesota

PFHxS

soil

SRV (incidental ingestion,

commercial/ industrial)

1700

ng/g

Minnesota

PFOA

sludge

screening level

2.5

ng/g

Maine

PFOA

air

screening level

ng/m3

Michigan

Screening level applies to the

concentration of PFOA and PFOS

combined

PFOA

groundwater

intervention limit (solid waste)

8.75

ng/L

Minnesota

Minnesota’s PFAS Blueprint • February 2021

181

PFAS

Media

Description

Value

Units

Source

Notes

PFOA

groundwater/ drinking

water

HRL (chronic)

ng/L

Minnesota

PFOA

soil

SRV (incidental ingestion,

residential/recreational)

240

ng/g

Minnesota

PFOA

soil

SRV (incidental ingestion,

commercial/ industrial)

3200

ng/g

Minnesota

PFOA

surface water

WQC (aquatic life, chronic)

1.70E+06

ng/L

Minnesota

PFOA

surface water

WQC (aquatic life, acute)

1.50E+07

ng/L

Minnesota

PFOA

Drinking water

Health advisory value

ng/L

EPA

Value applies to PFOA and PFOS

concentrations combined

PFOS

surface water

Federal Environmental Quality

Guideline (aquatic and

terrestrial life)

6800

ng/L

ECCC

PFOS

fish tissue

Federal Environmental Quality

Guideline (aquatic and

terrestrial life)

8300

ng/g

ECCC

PFOS

wildlife diet

(mammalian)

Federal Environmental Quality

Guideline (aquatic and

terrestrial life)

4.6

ng/g

ECCC

The wildlife diet guidelines are

intended to protect either

mammalian or avian species that

consume aquatic biota. It is the

concentration of PFOS in the aquatic

biota food item, expressed on whole

body, wet weight basis that could be

eaten by terrestrial or semi-aquatic

mammalian or avian wildlife.

PFOS

wildlife diet (avian)

Federal Environmental Quality

Guideline (aquatic and

terrestrial life)

8.2

ng/g

ECCC

PFOS

bird egg

Federal Environmental Quality

Guideline (aquatic and

terrestrial life)

1900

ng/g

ECCC

PFOS

milk

screening level

210

ng/L

Maine

Minnesota’s PFAS Blueprint • February 2021

182

PFAS

Media

Description

Value

Units

Source

Notes

PFOS

sludge

screening level

5.2

ng/g

Maine

PFOS

air

screening level

ng/m3

Michigan

Screening level applies to the

concentration of PFOA and PFOS

combined

PFOS

surface water

WQC (human health)

0.05

ng/L

Minnesota

PFOS

fish tissue

WQC (human health)

0.35

ng/g

Minnesota

PFOS

groundwater

intervention limits

3.75

ng/L

Minnesota

PFOS

groundwater/

drinking water

HRL (chronic)

300

ng/L

Minnesota

PFOS

groundwater/

drinking water

HBV (chronic)

ng/L

Minnesota

PFOS

soil

SRV (incidental ingestion,

residential/recreational)

ng/g

Minnesota

PFOS

soil

SRV (incidental ingestion,

commercial/industrial)

560

ng/g

Minnesota

PFOS

surface water

WQC (aquatic life, chronic)

19000

ng/L

Minnesota

PFOS

surface water

WQC (aquatic life, acute)

85000

ng/L

Minnesota

PFOS

Drinking water

Health Advisory level

ng/L

EPA

Value applies to PFOA and PFOS

concentrations combined

Minnesota’s PFAS Blueprint • February 2021

183

Appendix C. Relevant federal actions

Topic

Federal status

Citation

EPA is continuing to register new PFAS for use; Congress has proposed a

temporary moratorium on registration of new PFAS under TSCA but these

proposals have not been signed into law.

https://www.congress.gov/congressional-report/116th-congress/house-

report/364/1

Methods

EPA is working to publish additional validated PFAS analytical methods in

2021.

https://www.epa.gov/water-research/pfas-analytical-methods-

development-and-sampling-research

Quantifying

human health

risks

EPA is developing five PFAS risk assessments under the IRIS program

(PFBA, PFHxA, PFHxS, PFNA, and PFDA); the Office of Water is finalizing a

draft risk assessment for the GenX chemicals, and the Superfund program

(PPRTV) is finalizing a proposed risk assessment for PFBS. EPA and NIH

researchers are working together to use new chemical testing approach

methods to test 150 PFAS. The testing is quickly generating toxicity,

toxicokinetic and other types of data to help inform decisions made

about the potential health effects of PFAS.

https://cfpub.epa.gov/ncea/iris_drafts/recordisplay.cfm?deid=345065

https://www.epa.gov/pfas/genx-and-pfbs-draft-toxicity-assessments

https://www.epa.gov/chemical-research/pfas-chemical-lists-and-tiered-

testing-methods-descriptions

Drinking water

EPA has started the rulemaking process to regulate PFOA, PFOS, and

potentially additional PFAS under the Safe Drinking Water Act. EPA is

requiring monitoring for PFAS under the Unregulated Contaminant

Monitoring Rule (UCMR).

https://www.federalregister.gov/documents/2020/03/10/2020-

04145/announcement-of-preliminary-regulatory-determinations-for-

contaminants-on-the-fourth-drinking-water

https://www.epa.gov/dwucmr/development-fifth-proposed-

unregulated-contaminant-monitoring-rule-ucmr-5-public-water

Exposure from

fish and game

consumption

With regards to ensuring safe consumption of fish, EPA's PFAS action plan

states that the Agency will "determine if available data and research

support the development of Clean Water Act Section 304(a) ambient

water quality criteria for human health for PFAS" by 2021. EPA is taking

no action related to ensuring the safety of game consumption.

https://www.epa.gov/pfas/epas-pfas-action-plan

Exposure from

food

FDA has conducted some PFAS monitoring in food, but has not

incorporated PFAS into the regular Total Diet Study monitoring program.

FDA has coordinated voluntary phase-outs of some PFAS in food

packaging, but continues to allow PFAS in food packaging generally.

https://www.fda.gov/food/chemicals/and-polyfluoroalkyl-substances-

pfas

Risks from air

emission

EPA mandated reporting of some PFAS from some facilities under TRI

starting in 2021, but reporting exemptions mean that many meaningful

PFAS emissions will not be reported.

https://www.epa.gov/toxics-release-inventory-tri-program/list-pfas-

added-tri-ndaa

Minnesota’s PFAS Blueprint • February 2021

184

Topic

Federal status

Citation

Ecosystem health

EPA is not conducting ecological risk assessments for PFAS.

Remediation

EPA has a proposed rulemaking to include PFOA and PFOS as

"hazardous substances" under CERCLA. There has been no action to

finalize this proposed rule.

https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201910&

RIN=2050-AH09

Waste

EPA has issued technical briefs on PFAS incineration and other PFAS

disposal options. EPA is conducting a risk assessment for PFOA and

PFOS in biosolids.

https://www.epa.gov/chemical-research/technical-brief-and-

polyfluoroalkyl-substances-pfas-incineration-manage-pfas-waste

https://www.epa.gov/newsreleases/epa-releases-interim-guidance-

destroying-and-disposing-certain-pfas-and-pfas-containing ;

https://www.epa.gov/biosolids/risk-assessment-pollutants-

biosolids#pfas