Ohio Per- and Polyfluoroalkyl
Substances (PFAS) Action Plan
for Drinking Water
December 2019
Ohio Per- and Polyfluoroalkyl Substances (PFAS) Action Plan for Drinking Water December 2019
Table of Contents
Executive Summary ......................................................................................................................................................................................................... 1
Introduction ........................................................................................................................................................................................................................ 2
Per- and Polyfluoroalkyl Substances (PFAS) .................................................................................................................................................. 2
Public and Private Water System Oversight .................................................................................................................................................... 2
PFAS in Ohio .................................................................................................................................................................................................................. 2
PFAS Action Plan — Objectives and Strategies ................................................................................................................................................... 4
Objective 1: Gather sampling data from public water systems statewide to determine if PFAS is present in
drinking water. ............................................................................................................................................................................................................. 4
Objective 2: Assist private water system owners with guidelines and resources to identify and respond to
potential PFAS contamination. .............................................................................................................................................................................. 4
Objective 3: Establish Action Levels for drinking water in Ohio to aid in appropriately responding to PFAS
contamination for the protection of public health........................................................................................................................................ 4
Objective 4 — Work with Ohio communities to identify resources to assist their public water systems in
implementing preventative and long-term measures to reduce PFAS-related risks. ................................................................... 6
Objective 5 — Develop and disseminate educational information to the public to increase awareness and
understanding of PFAS-related compounds and relative risk of exposure to PFAS through drinking water and
other exposure pathways. ....................................................................................................................................................................................... 6
Objective 6 — Continue ongoing engagement to ensure this action plan for Ohio is adapted as the scientific
body of knowledge expands and the regulatory framework progresses at the national level. ................................................ 6
List of Tables
Table 1 — Ohio PFAS Action Levels ......................................................................................................................................................................... 5
Table 2 — Summary of Agency Responsibilities ................................................................................................................................................ 5
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Ohio Per- and Polyfluoroalkyl Substances (PFAS) Action Plan for Drinking Water December 2019
List of Acronyms
CCR Consumer Confidence Report
CWS community water systems
DDAGW Ohio EPA’s Division of Drinking and Ground Waters
DES Ohio EPA’s Division of Environmental Services
EPA Environmental Protection Agency (state – Ohio EPA, federal – U.S. EPA)
HAL health advisory level
LHD local health department
MCL maximum contaminant level
MRL method reporting limits
NTNC non-transient, non-community systems
OAC Ohio Administrative Code
ODH Ohio Department of Health
ORC Ohio Revised Code
PFAS per- and polyfluoroalkyl substances
PPT parts per trillion
PWS public water system
QAPP quality assurance project plan
SWAP Source Water Assessment and Protection
WPAFB Wright-Patterson Air Force Base
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Ohio Per- and Polyfluoroalkyl Substances (PFAS) Action Plan for Drinking Water December 2019
Executive Summary
Ohio and states nationwide are faced with challenges
related to per- and polyfluoroalkyl substances (PFAS), Action Plan Objectives
which have been manufactured and used for years in
everyday items such as nonstick cookware, water- Gather and provide sampling data from
resistant clothing and personal care products. PFAS specific types of public water systems to
chemicals have also been widely used in firefighting determine if PFAS is present in raw and
foams, at military installations and fire training facilities. finished drinking water.
On Sept. 27, 2019, Governor Mike DeWine announced Assist private water system owners with
the establishment of an inter-agency workgroup to guidelines and resources to identify and
address the emerging issue of PFAS in Ohio, both for the respond to potential PFAS contamination.
protection of our natural resources and public health. In Establish Action Levels for drinking water
his announcement, he directed the Ohio Environmental systems in Ohio to aid in appropriately
Protection Agency (Ohio EPA) and Ohio Department of responding to PFAS contamination for the
Health (ODH) to work together on developing a protection of public health.
statewide PFAS action plan to address potential threats Work with Ohio communities to identify
to both public and private drinking water systems. resources to assist their public water systems
In developing the action plan, Ohio EPA and ODH will in implementing preventative and long-term
work with other key stakeholders to more fully evaluate measures to reduce PFAS-related risks.
the risks of PFAS in Ohio and assist our communities in Develop and disseminate educational
addressing these risks. information to the public to increase
While the initial focus of the action plan is on potential awareness and understanding of PFAS-
risks associated with PFAS in drinking water, there are related compounds and relative risk of
other emerging areas of national research related to exposure to PFAS through drinking water and
PFAS, including identifying safer chemical substitutes other exposure pathways.
for PFAS, soil remediation technologies and other Continue ongoing engagement to ensure this
treatment methods to address PFAS. action plan for Ohio is adapted as the
scientific body of knowledge expands and
Earlier this year, Governor DeWine, along with 14
governors signed a letter to both the United States the regulatory framework progresses at the
Senate and House Armed Services Committees calling national level.
for more comprehensive national legislation on PFAS
and action to address PFAS contamination in and around military bases.
To this end, Ohio EPA and ODH will keep abreast on these developments and ensure this plan is adapted as
the science and the national regulatory framework on PFAS unfolds.
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Ohio Per- and Polyfluoroalkyl Substances (PFAS) Action Plan for Drinking Water December 2019
Introduction
Per- and Polyfluoroalkyl Substances (PFAS)
PFAS is a family of over 4,000 man-made chemicals that have been used in a variety of industrial, commercial
and consumer products. With strong carbon-fluorine bonds, these chemicals are extremely effective in
making everyday items more resistant to stains, grease, and water. They have been widely used to
manufacture paper and cardboard packaging, carpeting, leather products, textiles and personal care
products. They are used extensively in the manufacture of materials that have non-stick properties. PFAS
have also been widely used in fire suppression foams. Two specific chemicals of the PFAS family, PFOA and
PFOS have been the most extensively produced and most widely studied to date.
The major source of exposure to PFAS is through ingestion. Data suggest that PFAS are not easily or readily
metabolized by the human body and are commonly found in human blood across the nation. With more
scientific data emerging on PFAS, studies indicate that potential health risks associated with PFAS exposures
can include liver damage, thyroid disease, elevated cholesterol, decreased antibody response to vaccines, and
pregnancy-induced hypertension, decreased fertility and small decreases in birthweight, developmental and
immune toxicity.
While PFAS do not occur naturally, they may be found throughout the environment due to a long history of
manufacturing and use. PFAS chemicals are very stable and do not easily biodegrade. PFAS contamination in
soils is of particular concern for drinking water due to potential impacts to surface and ground water
sources.
Public and Private Water System Oversight
Public water systems are regulated by the Ohio EPA. Community water systems (CWS) serve at least 15
service connections used by year-round residents or regularly serve at least 25 year-round residents.
Examples include cities, mobile home parks and nursing homes. Non-transient, non-community systems
(NTNC) serve at least 25 of the same persons over six months per year. Examples include schools, hospitals
and factories.
Private water systems are regulated by the ODH. Private water systems are defined as any water system for
the provision of water for human consumption, if the system has fewer than 15 service connections and does
not regularly serve an average of at least 25 individuals at least 60 days out of the year (e.g. private homes,
small churches, etc.).
PFAS in Ohio
The Safe Drinking Water Act requires U.S. EPA to identify up to 30 unregulated contaminants to be
monitored by public water systems every five years, to provide a basis for future regulatory actions to
protect public health. The third cycle of the Unregulated Contaminant Monitoring Rule required monitoring
for 28 chemicals and included six PFAS chemicals. In Ohio, 186 public water systems participated in the
monitoring during 2013-2015. As a result of this sampling, one public water system serving Wright-
Patterson Air Force Base (WPAFB) reported PFAS at elevated levels.
In 2016, the U.S. EPA set a health advisory level (HAL) of 70 parts per trillion (ppt) for PFOA and PFOS in
drinking water to help ensure sensitive populations were protected from adverse health effects associated
with these chemicals. While a HAL has been established for these chemicals, U.S. EPA is working on a
national framework to set regulatory standards for PFAS, including national safe drinking water standards
(known as a maximum contaminant level or MCL).
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Ohio Per- and Polyfluoroalkyl Substances (PFAS) Action Plan for Drinking Water December 2019
The establishment of the HAL prompted additional coordination between Ohio EPA, communities and
military installations to gather more information on potential PFAS risks in drinking water. There has been
ongoing data collection, assessment efforts and coordination between WPAFB, Ohio EPA and the City of
Dayton to monitor impacts to public water systems that serve both WPAFB and the City of Dayton.
As a proactive measure, the Ohio National Guard also worked with Ohio EPA to obtain sample results for
private water supply wells near its bases, including former fire training areas, to ensure that these wells
were not contaminated by PFAS. As a result of this sampling, one private well near the Toledo Air National
Guard base was connected to a public water system due to the detection of contamination.
PFAS contamination has also been identified from manufacturing activities associated with the Chemours
(formerly known as DuPont) Washington Works facility, located near Parkersburg, West Virginia.
Remediation requirements, including treatment for several public and private water supply systems are
included in a federal consent order, entered into between U.S. EPA, Chemours and DuPont.
Ohio’s statewide action plan will focus on gathering additional data to assist in identifying, responding to and
communicating PFAS-related drinking water risks in Ohio. This plan has been developed and will be
implemented in partnership between Ohio EPA and ODH.
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Ohio Per- and Polyfluoroalkyl Substances (PFAS) Action Plan for Drinking Water December 2019
PFAS Action Plan — Objectives and Strategies
Objective 1: Gather sampling data from public water systems statewide to determine if PFAS is
present in drinking water.
Ohio EPA will coordinate sampling of approximately 1,500 public water systems statewide. These systems
provide water to cities, mobile home parks, schools, and daycares and serve approximately 90 percent of
Ohio’s population.
Raw and finished water samples will be collected at these public water systems, with a goal of completing
sampling efforts by the end of 2020. Finished water samples will be collected at an entry point to the
distribution system, which is a location in the public water system after treatment or chemical addition.
Sampling efforts will be coordinated by Ohio EPA under contracts with qualified consultants and
laboratories. Contract labs will conduct analyses in accordance with a quality assurance project plan (QAPP)
and U.S. EPA-approved methods for drinking water. Some sampling may also be conducted by trained
technicians from Ohio EPA and analyzed by Ohio EPA’s Division of Environmental Services (DES), which has
also been approved for U.S. EPA methods.
PFAS sampling results for public water systems will be published on Ohio’s PFAS web page to allow public
access to the data.
Objective 2: Assist private water system owners with guidelines and resources to identify and
respond to potential PFAS contamination.
ODH will evaluate the PFAS source water results from the public water systems sampled by Ohio EPA. If the
data suggest that nearby private water system sources may potentially be contaminated, ODH will
coordinate with local health districts and private water system owners for appropriate response measures,
including providing guidance on testing recommendations and steps to reduce risks, including treatment
options for private water systems.
ODH has established fact sheets, guidance and videos for the public related to health effects from exposure to
PFAS, ways the public can reduce their exposures, and information on systems available to private water
system owners for the treatment and removal of PFAS. These materials and other PFAS resources will be
available and updated, as needed, on Ohio’s PFAS webpage.
Objective 3: Establish Action Levels for drinking water in Ohio to aid in appropriately
responding to PFAS contamination for the protection of public health.
There are currently no national drinking water standards for PFAS compounds. The establishment of
national drinking water standards, called Maximum Contaminant Levels or MCLs, is under consideration by
U.S. EPA. In 2016, U.S. EPA set Health Advisory Levels (HALs) of 70 parts per trillion (ppt) for two of the
most studied PFAS chemicals, PFOA and PFOS. In Table 1, the Ohio Action Levels for PFOA and PFOS utilize
the established U.S. EPA HALs. Because HALs are not available for other PFAS chemicals at this time, the Ohio
Action Levels for GenX, PFBS, PFHxs, and PFNA are calculated using the U.S. EPA’s established Drinking
Water Equivalent Level method and toxicity data. These levels will be re-evaluated as U.S. EPA finalizes
toxicity assessments. Additional information used to develop the action levels will be provided on Ohio’s
PFAS web page.
Ohio EPA and ODH will use these action levels as thresholds in providing guidance to drinking water system
owners/operators in mitigating health risks.
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Ohio Per- and Polyfluoroalkyl Substances (PFAS) Action Plan for Drinking Water December 2019
Table 1 — Ohio PFAS Action Levels
PFAS Chemicals1
PFOA PFOS GenX PFBS PFHxS PFNA
Action Level (ppt) >70 single or >70 single or combined > 700 >140,000 > 140 > 21
combined with PFOS with PFOA
Ohio EPA will be establishing response protocols for public water systems in Ohio when action levels are
exceeded, including public notification and issuance of drinking water advisories. ODH will be establishing
response protocols to PFAS detections for private water systems in Ohio when action levels are exceeded.
Table 2 summarizes agency responsibilities in sampling and responding to PFAS detections and exceedances
in drinking water at public and private water systems.
Table 2 — Summary of Agency Responsibilities
Ohio EPA Responsibilities ODH Responsibilities
Event (Public Water Systems) (Private Water Systems)
Sampling and Develop and implement statewide public Review public water system raw sample data in
Data Collection water system sampling plans. coordination with Ohio EPA to evaluate potential
Coordinate sampling with public water contamination of private water systems.
systems.
Ensure results posted and available to the
public in a timely manner.
PFAS Detection Notify the public water system and ODH of Notify private water system owners of
detections. detections in coordination with local health
Work with the public water system to develop districts.
approaches to address PFAS source and Provide information to affected homeowner(s)
establish monitoring frequency. on potential PFAS health effects and ways to
reduce exposures.
Action Level Public water system notifies consumers of Notify private water system owners of action
Exceeded results and advice using Ohio EPA templates. level exceedances in coordination with local
Work with the public water system to identify health districts.
and implement short-term and long-term Work with private water system owners to
response measures to reduce exposure risks, identify appropriate short-term and long-term
including source water management and measures to reduce exposures.
treatment.
Detection levels are based on the lowest achievable method reporting limits (MRL) by the laboratory. A
survey of state and federal laboratories taken at the writing of this document indicate achievable MRLs for
PFOA is 5 ppt, PFOS is 5 ppt, GenX is 25 ppt, PFBS is 5 ppt, PFHxS is 5 ppt and PFNA is 5 ppt.
11 PFOA (Perfluorooctanoic Acid), PFOS (perfluorooctane Sulfonate), GenX (HFPO dimer acid), PFBS (perfluorobutanesulfonic acid),
PFHxS (perfluorohexane sulfonic acid), and PFNA (perfluorononanoic acid).
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Ohio Per- and Polyfluoroalkyl Substances (PFAS) Action Plan for Drinking Water December 2019
Objective 4 — Work with Ohio communities to identify resources to assist their public water
systems in implementing preventative and long-term measures to reduce PFAS-related risks.
Ohio EPA’s Division of Environmental and Financial Assistance will provide communities with information
on available loans and technical assistance to help communities with planning, design and installation of
treatment or other infrastructure improvements.
Ohio EPA will work with communities to support and develop source water protection capabilities, including
conducting source water protection workshops to help communities understand measures they can take to
identify potential sources of PFAS contamination and preventative measures to reduce impacts to their
drinking water sources.
ODH will coordinate with Ohio EPA and other stakeholders to identify potential resources available to assist
private water system owners with sampling and analysis for PFAS, and installation and maintenance of
water treatment systems.
Objective 5 — Develop and disseminate educational information to the public to increase
awareness and understanding of PFAS-related compounds and relative risk of exposure to
PFAS through drinking water and other exposure pathways.
Ohio EPA and ODH will collaborate in developing and disseminating educational information to increase
awareness and understanding of PFAS-related compounds and relative risk of exposure to PFAS through
drinking water and other exposure pathways. The public will receive this information through a PFAS web
page, social media, and other communication vehicles. Topics will include:
Results/data from public water system sampling;
Health-based information on PFAS exposure and risks;
Interpretation of detections;
Information on reducing potential exposure risks;
Public and private water systems toolkits directing responses to detections and action level
exceedances;
Technical support documentation and helpful resources;
Guidelines and educational information for private water system owners; and
Updates on PFAS-related activity occurring at the national level.
Objective 6 — Continue ongoing engagement to ensure this action plan for Ohio is adapted as
the scientific body of knowledge expands and the regulatory framework progresses at the
national level.
While the initial focus of the action plan is on potential risks associated with PFAS in drinking water, there
are other emerging areas of national research related to PFAS, including development of analytical methods,
identifying safer chemical substitutes for PFAS, addressing other exposure pathways, and PFAS treatment
and remediation technologies.
To this end, Ohio EPA and ODH will keep abreast on these developments and ensure the plan is adapted as
the science and the national regulatory framework on PFAS unfolds. Both agencies will also continue to
network with research organizations and other states in advancements in the understanding of PFAS to
determine future actions to protect natural resources and public health in Ohio.
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