California Platers Engage Regional Water Boards on PFAS Sampling Order

The California State Water Control Board and regional water boards are in the process of implementing 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 based on the model template have been approved, facilities have received revised Work Plans from regional water boards that included extensive soil and groundwater sampling.  Some of the regional water boards are now requiring facilities to conduct all sampling at the same time, which could include costs that exceed $50,000 per facility.  In addition, some facilities have been threatened with civil penalties if they did not comply with the onerous drilling requirements.  This is clearly inconsistent with the phased approach that was initially approved by the water boards.

NASF and its California Chapters have raised concerns about this expansive approach to PFAS sampling to Los Angeles Regional Water Board officials at public hearings and scheduled calls. 

In addition, the California Chapters recently submitted a letter to the L.A. Regional Water Board that highlighted key concerns, sought further justification for requiring subsurface soil and groundwater sampling, and asked the board to reconsider its approach to PFAS sampling for surface finishing facilities.  

NASF and its Chapters will continue to facilitate compliance with the state order and to minimize the burden on surface finishing facilities. 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.