The PFAS Dilemma
Paul Jacobi and Eric Jacobi
I am not blaming DEEP for creating a very serious dilemma. PFAS are everywhere. If you are a Transfer Act site and you fall into one of many industrial categories, you must test for these compounds. However, if you find PFAS in groundwater, you likely cannot successfully verify a site without upgradient soil and/or groundwater samples to establish background levels—even if the concentrations identified are extremely low.
Sampling is required for 25 PFAS compounds. However, groundwater protection criteria have only been established for 5 compounds. It gets worse: there are no applicable surface water protection criteria at all. Zero!
I have found the Agency sympathetic to the plight of the regulated community, which cannot easily buy or sell these properties. However, their hands are tied as well. This dilemma will not change even if the Transfer Act is eventually sunset. That will not take away the need for releases to comply with standards that do not exist.
As USEPA considered this a major public health concern under Biden, it is apparently now not even a low priority under Trump. If EPA won’t develop standards, the state legislature must take this responsibility on. They should take counsel from DEEP and work with the Agency to promptly develop standards.
If the state is not willing to invest the funds needed to adopt scientifically appropriate standards, then it should not require investigation and remediation of PFAS sites which cannot possibly be verified. This is completely unfair to Connecticut businesses.
