California Platers Begin Sampling of PFAS Pursuant to Water Board Orders

The California State Water Control Board recently issued an order to chromium platers in California to sample for PFAS compounds.  NASF and its California Chapters negotiated a model Work Plan for facilities to use in conducting sampling.  The Work Plan that was reviewed and approved by the State and Regional Water Boards included a phased approach to sampling.  Under this approach, facilities would first sample wastewater and stormwater to determine if PFAS were present.  These sampling results would determine if it was necessary to conduct the more expensive soil and groundwater sampling.  The approach was designed to minimize the burden on small businesses and avoid more expensive and invasive drilling sampling if the preliminary results indicated that PFAS were not detected above levels of concern.

While many Work Plans were submitted last year, progress on this effort was delayed due to the pandemic.  More recently, facilities had received revised Work Plans from regional water boards that included extensive soil and groundwater sampling.  Despite having approved the phased approach to sampling, the regional water boards are now requiring facilities to conduct all sampling at the same time, regardless of results.  In addition, there has been inconsistent implementation of responses from regional water boards, including no response to claims to be excluded, no response to Work Plans that have been submitted, and the return of revised Work Plans. 

In response to industry concerns, a meeting has been scheduled with one of the regional water boards that has issued revised Work Plans requiring drilling into soil and groundwater.  NASF and its California Chapters will work toward a reasonable resolution to minimize the burdens on surface finishing facilities while meeting the requirements of the order.  If you have any questions or would like additional information on this matter, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com. 

This update is courtesy of the National Association for Surface Finishing (NASF). For more information or to become a member, visit nasf.org.