PFAS

There are two concurrent PFAS sampling efforts happening in the State of Tennessee:

  1.  The Tennessee Department of Environment and Conservation's (TDEC) PFAS Statewide Sampling Effort
  2.  The Environmental Protection Agency's (EPA) Fifth Unregulated Contaminant Monitoring Rule (UCMR 5) 

See below for additional information about these two distinct efforts.

  TDEC Statewide Sampling EPA UCMR 5
Lead Agency TDEC EPA
Sample Source Raw (Source; Untreated) Water Finished Drinking Water
PFAS Sampled 29 PFAS 29 PFAS and Lithium
Analytical Methods EPA Methods 533 and 537.1 EPA Methods 533 and 537.1
Systems Included

All Public Drinking Water Systems

Public Drinking Water Systems...
  • Serving 10,001 or More Customers
  • Serving 3,301 to 10,000 Customers if Confirmed by EPA
  • A Nationally Representative Sample Serving Fewer than 3,000 Customers
How to Access the Data
Additional Resources
For More Information Contact TDEC Contact EPA

What are PFAS?

Per- and polyfluoroalkyl substances, known as PFAS, are a group of thousands of man-made chemicals that have been manufactured for a variety of consumer and industrial uses in the United States since the 1940s. PFAS provide grease and water-resistance properties to carpets, cookware, clothing, food packaging, cosmetics, and other common consumer products. PFAS also have many industrial applications and are used to make certain types of firefighting foams.

Some common types of PFAS include:

  • Perfluorooctanoic acid (PFOA)
  • Perfluorooctanesulfonic acid (PFOS)
  • Perfluorobutane sulfonic acid (PFBS)
  • Hexafluoropropylene oxide dimer acid (“GenX chemicals”)

Why are we concerned about PFAS?

  • PFAS are widely used, long lasting or “forever” chemical, components of which break down very slowly over time.
  • PFAS contamination can migrate to groundwater and surface water, potentially impacting drinking water sources.
  • Because of their widespread use and persistence in the environment, many PFAS are found in the blood of people and animals all over the world and are present at variable levels in a variety of food products and in the environment.
  • Unsafe storage, improper disposal, and inadequate containment has resulted in contamination of soil, water, and air in some locations.
  • Scientific studies have shown that exposure to some PFAS in the environment may be linked to harmful health effects in humans and animals.

For more information on the possible health effects of PFAS and recommendations to protect Human Health, visit the Tennessee Department of Health’s PFAS Website.


How did PFAS end up in our environment?

PFAS can be found in air, soil, and/or water. The most significant sources of known PFAS contamination are facilities that manufacture these chemicals and military bases that conduct extensive firefighting training activities. In certain locations, a lack of adequate waste storage and disposal practices at chemical manufacturing facilities has resulted in further contamination of groundwater and surface water.

PFAS are found in many consumer products due to water- and grease- resistant properties. Examples of its use in products include:

PFAS in Consumer Products
PFAS in Consumer Products. From left to right: stain resistant products, nonstick cookware, takeout containers, waterproof apparel, furniture and textiles, firefighting foam.

Certain PFAS chemicals are no longer manufactured in the United States as a result of their persistence in the environment. However, many of these products are still produced internationally and can be imported into the United States in consumer goods such as carpet, leather and apparel, textiles, paper and packaging, coatings, rubber and plastics.


How are people exposed to PFAS?

PFAS Exposure Pathways
PFAS Exposure Pathways. From left to right: working in an industrial facility where PFAS chemicals were produced or used, drinking contaminated municipal water or private well water, eating fish caught from water contaminated by PFAS chemicals, eating food that has been contaminated during growing, packaging, and/or processing, accidentally swallowing contaminated soil or dust.

Most people are exposed to PFAS primarily through drinking beverages or eating food made with contaminated water or exposure to PFAS in dust or consumer products. Exposure impacts from skin contact and inhalation of water droplets are expected to be minor.


How are PFAS regulated?

On March 14, 2023, The U.S. Environmental Protection Agency (EPA) proposed a National Primary Drinking Water Regulation and health-based Maximum Contaminant Level Goals (MCLGs) for six PFAS: PFHxS, HFPO-DA, GenX, PFNA, PFOA, and PFOS. EPA proposed individual Maximum Contaminant Levels (MCLs) of 4.0 ppt for PFOA and PFOS and proposed to use a Hazard Index approach for the mixture of PFHxS, HFPO-DA (GenX), PFNA, and PFBS, setting it at 1.0. EPA anticipates finalizing the rule by the end of 2023 or early 2024. To learn more about EPA's proposed rule, visit the PFAS National Primary Drinking Water Regulation Rulemaking page through the Federal Register.

Compound Proposed MCLG Proposed MCL (enforceable)
PFOA Zero 4.0 ppt
PFOS Zero 4.0 ppt

PFNA

PFHxS

PFBS

HFPO-DA (GenX)

1.0 (unitless) Hazard Index 1.0 (unitless) Hazard Index

The State of Tennessee does not currently regulate PFAS in drinking water.

For more information, see “How are Other Agencies Responding to PFAS.”


How is TDEC responding to PFAS?

TDEC is taking several steps to address PFAS in Tennessee.

  • TDEC is conducting a statewide sampling initiative to test all public drinking water sources for 29 PFAS compounds. TDEC Division of Water Resources (DWR) staff located in TDEC’s eight environmental field offices across the state are taking samples for this initial assessment, which will help TDEC understand the presence and concentration of PFAS compounds in source waters throughout the state.  In addition to understanding potential presence of PFAS in Tennessee, the results of this effort will help both TDEC and the regulated community understand how to reduce human exposure to PFAS via drinking water. TDEC will publicly publish assessment results  as they become available. At the conclusion of the assessment, TDEC will publish a report summarizing data and results on this page.
  • TDEC formed an interdisciplinary working group to identify potential activities likely to contribute to PFAS contamination and determine the agency’s best course of action for protecting Tennesseans from adverse health effects resulting from PFAS contamination. The working group consists of representatives from state and federal government, non-profits, private industry, and academia.

How are other agencies responding to PFAS?

Proposed Rulemaking for PFAS Hazardous Constituents under RCRA

On February 8, 2024, the US EPA proposed to amend its regulation under the Resource Conservation and Recovery Act (RCRA) by adding 9 specific per-and polyfluoroalkyl substances (PFAS), their salts, and their structural isomers to its list of hazardous constituents. The EPA’s rule proposes that the following 9 PFAS be regulated as hazardous constituents under RCRA*: Perfluorooctanoic acid (PFOA), Perfluorooctanesulfonic acid (PFOS), Perfluorobutanesulfonic acid (PFBS), Hexafluoropropylene oxidedimer acid (HFPO–DA or GenX), Perfluorononanoic acid (PFNA), Perfluorohexanesulfonic acid (PFHxS), Perfluorodecanoic acid (PFDA), Perfluorohexanoic acid (PFHxA), and Perfluorobutanoic acid (PFBA).

*Listing these PFAS as RCRA hazardous constituents does not make them, or the wastes containing them, RCRA hazardous wastes.

Entities potentially affected by this action include hazardous waste treatment, storage, and disposal facilities (TSDFs) with solid waste management units that have released or could release any of the PFAS proposed to be listed as RCRA hazardous constituents. RCRA section 3004(u) requires that any permit issued to TSDFs after November 8, 1984, require corrective action for all releases of hazardous waste or hazardous constituents from solid waste management units at the facility. EPA has identified 1,740 such facilities, which could be subject to additional corrective action requirements (pursuant to RCRA section 3004(u) and (v)) to address releases not already subject to corrective action pursuant to EPA’s corrective action regulations. This proposed rule is open for public comment until April 8, 2024.

Final Rule Under the Toxic Substance Control Act (TSCA)

On September 28, 2023, the US EPA issued a final rule under the Toxic Substance Control Act (TCSA) to require reporting and recordkeeping for all imported and manufactured PFAS or PFAS-containing products for commercial purposes. This is applicable to all PFAS or PFAS-containing products manufactured since January 1, 2011, whether manufactured domestically or imported. The effective date for this rule is November 13, 2023. All entities, including small entities, have 18 months from the effective date (May 8, 2025) to report PFAS data to the EPA. Small manufacturers (as defined per 40 CFR 704.3) whose reporting obligations under this rule are exclusively from article imports will have 24 months from the effective date of this rule to report PFAS to EPA (November 10, 2025). EPA estimates that recordkeeping and reporting of at least 1,462 compounds will be covered under this rule.

Unregulated Contaminant Monitoring Rule (UCMR)

A requirement of the 1996 Safe Drinking Water Act (SDWA) amendments, the Unregulated Contaminant Monitoring Rule (UCMR) provides EPA authority to collect data on unregulated contaminants that are suspected of being present in drinking water and do not have health-based standards under the SDWA. Occurring once every 5 years, a total of 4 separate UCMR sampling events have been completed since it began in 2001, with a fifth currently underway (2023-2025).

Conducted from 2018-2020, EPA’s Fourth Unregulated Contaminant Monitoring Rule (UCMR4) sampling event, sampled for 6 different PFAS for which the EPA has proposed Maximum Contaminant Levels (MCLs) in finished drinking water nationwide. EPA anticipates finalizing the regulation by the end of 2023. EPA’s Fifth Unregulated Contaminant Monitoring Rule (UCMR5) sampling event is currently active. EPA will utilize UCMR5 data to inform research priorities for PFAS found in drinking water. Under this initiative, Tennessee water systems are continuing all existing monitoring efforts while additionally adding monitoring efforts for lithium per UCMR5 requirements.

On August 17, 2023, EPA released the first UCMR5 dataset representing approximately 7% of the total sample results expected under UCMR5. For this dataset and more information about UCMRs, including reports and raw data, click here.

For Tennessee specific data regarding ongoing monitoring and testing of raw (source) water, please visit our TDEC PFAS dashboard.

Proposed Rulemaking for PFAS National Primary Drinking Water Regulations

EPA proposed drinking water regulations for six PFAS: PFOA, PFOS, PFHxS, HFPO-DA (GenX), PFNA, and PFBS. The proposed Maximum Contaminant Levels (MCLs) are 4.0 ppt for PFOA and PFOS and utilize a Hazard Index of 1.0 for the mixture of PFHxS, HFPO-DA, GenX, and PFBS. EPA anticipates finalizing this regulation in late 2023 or early 2024.

Proposed Rulemaking to Designate PFOA and PFOS as Hazardous Substances under CERCLA

EPA proposed to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund, with a final designation expected in 2023.  

Drinking Water Health Advisories for Four PFAS

In June 2022, EPA issued new and updated non-regulatory drinking water health advisories for four PFAS chemicals based on the agency’s assessment of the latest peer-reviewed science and health data. EPA released interim updated drinking water lifetime health advisories for PFOA and PFOS that replace those issued by EPA in 2016. At the same time, EPA also issued final health advisories for two other PFAS, perfluorobutane sulfonic acid and its potassium salt (PFBS), and for hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt (“GenX chemicals"). In chemical and product manufacturing, GenX chemicals are considered a replacement for PFOA, and PFBS is considered a replacement for PFOS. These new and updated advisory levels, based on new data considering lifetime exposure, indicate that some negative health effects may occur by consuming water with concentrations of PFOA or PFOS near zero. To provide Americans, including the most sensitive populations, with a margin of protection from a lifetime of exposure to PFAS from drinking water, EPA has established the following health advisory levels for four PFAS chemicals:

  1. PFOA: 0.004 ppt
  2. PFOS: 0.02 ppt  
  3. PFBS: 2,000 ppt
  4. GenX: 10 ppt

For more information the EPA health advisory levels for PFAS, please see the EPA Questions and Answers: Drinking Water Health Advisories for PFOA, PFOS, GenX Chemicals and PFBS webpage.

Regional Screening Levels and Removal Management Levels for PFAS at Superfund Sites

In May 2022, EPA announced the addition of five PFAS chemicals, for a total of six PFAS chemicals, to the list of Regional Screening Levels (RSL) and Regional Removal Management Levels (RML) for chemical contaminants at Superfund sites. RSLs are used to identify contaminated media (i.e., air, tap water, and soil) at a Superfund site that may need further investigation. In general, if a contaminant concentration is below the screening level no further action or investigation is needed. If the concentration is above the screening level, further investigation is generally needed to determine if some action is required. RMLs are used to support EPA’s decisions to undertake a removal action under CERCLA, such as providing alternative drinking water, or remediation of contaminated media, if necessary. Screening and removal management levels are not cleanup standards. They are risk-based values that help EPA determine if further investigation or actions are needed to protect public health, such as sampling, assessing risks, and taking further action, which could include providing alternative drinking water. These mechanisms allow site teams to make better site decisions that will protect nearby communities. The five PFAS additions include: GenX, PFOS, PFOA, perfluorononanoic acid (PFNA), and perfluorohexanesulfonic acid (PFHxS). For more information, visit EPA’s Regional Screening Levels for Chemical Contaminants at Superfund Sites and Regional Removal Management Levels for Chemicals webpages.

EPA’s PFAS Strategic Roadmap

In October 2021, EPA released the “PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024” which sets timelines by which EPA plans to take specific actions to address PFAS and to protect public health. The Strategic Roadmap describes EPA’s approach to addressing PFAS at the national level and describes the key actions EPA has underway and anticipates taking in the future to address PFAS. 

EPA’s PFAS Action Plan

In February 2019, EPA released the PFAS Action Plan which outlines steps the agency is taking to address PFAS and to protect public health. The Action Plan describes the EPA’s approach to identifying and understanding PFAS, approaches to addressing current PFAS contamination, preventing future contamination, and effectively communicating with the public about PFAS. The Action Plan describes the broad actions the EPA has underway to address challenges with PFAS in the environment and identifies more short-term and long-term actions that are currently being implemented to understand and address PFAS. 

PFAS Cleanup Assessments at Department of Defense Facilities

The Department of Defense (DOD) is currently conducting FPAS cleanup assessments at nearly 700 DOD installations and National Guard locations where PFAS was used or may have been released. These assessments include evaluation of historic records of PFAS use at installations, site inspections, and sampling of drinking water, groundwater or soil to determine the scope of PFAS contamination and need for mitigation and/or remediation action. DOD expects to complete all initial assessments by the end of 2023. 

Research and Development Program for PFAS Detection, Treatment and Destruction

DOD manages the largest research and development program in the nation devoted to PFAS detection, treatment, and destruction—with over $150 million in investments and another $70 million devoted to developing PFAS-free replacement firefighting foam. DOD is actively partnering with academic research institutions across the nation to develop the science to help manage PFAS. For more information please visit DOD's PFAS website

Department of Energy PFAS Management Policy

In September 2021, the Department of Energy (DOE) Deputy Secretary issued a policy memorandum that addresses PFAS management for DOE operations. The memorandum requires DOE to discontinue use of Aqueous Film-Forming Foam (AFFF) except for use in actual fire emergencies; to have fire protection personnel wear PFAS-protective personal protective equipment; to suspend disposal of waste containing PFAS; and to report PFAS-containing AFFF releases or spills to DOE’s Occurrence Reporting and Processing System which supports mission safety and field oversight. The policy also is intended to leverage the expertise of the National Laboratories to advance knowledge about PFAS contamination, its fate and transport in the environment, and innovative research and technological approaches to address it.

PFAS Strategic Roadmap

On August 18, 2022, DOE released the PFAS Strategic Roadmap:  DOE’s Commitments to Action 2022-2025, which outlines goals, objectives and specific actions the Department of Energy is taking to address risk from PFAS. DOE is also preparing an initial assessment report that will summarize the results of a preliminary evaluation of known historic or current PFAS uses, PFAS occurrence in the environment, and regulatory and stakeholder interactions at DOE program sites.

PFAS Exposure Assessments

The Centers for Disease Prevention and Control (CDC) and Agency for Toxic Substances and Disease Registry (ATSDR) conducted exposure assessments in communities known to have had PFAS levels in their drinking water in excess of the 2016 EPA health advisory levels. ATSDR conducted 10 PFAS exposure assessments, which looked at exposures in more than 2,300 individuals from over 1,400 households The primary goal of these exposure assessments was to provide information to communities about levels of PFAS in their bodies. For more information on the results of these assessments please visit the CDC's PFAS website

PFAS Scientific Research

The National Institute of Environmental Health Sciences (NIEHS) and the National Toxicology Program are supporting research to better understand many aspects of PFAS, including possible health effects, sources of exposure, and methods for removing the substances from the environment. NIEHS offers a publicly available, searchable database of published scientific papers about PFAS. 

The Interagency Policy Committee on PFAS

Led by the White House Council on Environmental Quality (CEQ), the Interagency Policy Committee on PFAS is designed to facilitate the high-level coordination of PFAS response activities across federal government agencies. The committee will work to coordinate and help develop new policy strategies to support research, remediation, and removal of PFAS in communities across the country. 


How can I learn more about PFAS?


Office of Policy & Planning Contacts


TDEC.PFAS@tn.gov

Emily Leonard

Office of Policy and Planning
Emily.Leonard@tn.gov
Phone: 615-854-0852

Division of Solid Waste Management Contact


Jeremy Hooper

Division of Solid Waste Management
Jeremy.Hooper@tn.gov 
Phone: 615-686-7847