On November 29, 2021, the Minnesota Pollution Control Agency (MPCA) discussed the air monitoring component of their draft PFAS (per- and polyfluoroalkyl substances) Monitoring Plan, issued earlier this month. The monitoring plan addresses issues identified in Minnesota’s PFAS Blueprint, released in February 2021.
During the PFAS air monitoring webinar, the MPCA announced that air permit holders in certain industries will be required to report PFAS emissions beginning with reporting year 2022, and some sources will be asked to perform voluntarily stack testing to identify PFAS emissions. Those affected could include wastewater treatment plants, paper mills, manufacturing facilities, petroleum refineries, airports, landfills, solid waste combustors, and more.
At Barr, we work with clients and regulators to help develop a clear understanding of PFAS and hone the scope of data-collection efforts to focus on providing accurate information and developing long-term solutions. As a leader in addressing PFAS issues in air, water, soil, and biosolids, we left the webinar with the following takeaways:
- Confidentiality. PFAS testing and quantification has, to date, often been conducted with confidentiality protections, due to the litigious nature of the topic. In addition, raw material composition can be considered a trade secret. Barr has frequently worked with clients and their legal counsel to manage data collection and analysis in a manner that allows clients to balance confidentiality strategies with project requirements.
- Availability of information. We've often found PFAS in raw materials at concentrations below the threshold for mandatory inclusion in a safety data sheet. As a result, preparing PFAS emission calculations is not as simple as reviewing safety data sheets. Barr has worked with clients to interpret safety data sheets to identify materials that will require more detailed compositional information. This can also cause confidentiality concerns for the vendors, and we can help you navigate those issues along with your vendors.
- Stack testing. Many sites will receive requests to perform Other Test Method 45 (OTM-45) measurements of PFAS substances in 2022. Barr has been engaged with the development of stack testing methods for PFAS since the early 2000s and recently conducted stack testing using OTM-45.
Since the early 2000s, Barr has developed and implemented highly effective multi-media PFAS detection, monitoring, remediation, and treatment solutions for industrial clients and municipalities. For an overview of recent projects, visit our PFAS Innovation & Insights page.
We will continue to monitor PFAS developments in Minnesota. For more information, contact us at PFAS@barr.com.