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Per- and Polyfluoroalkyl Substances (PFAS) are a class of synthetic chemicals that have been used for decades but are the subject of new and evolving regulations in recent years. Earlier this year, the EPA added 172 new PFAS chemicals to the list of RY2020 reportable chemicals under Toxic Release Inventory (TRI) reporting. The new reporting requirements have implications for a wide range of industrial processes where PFAS chemicals are used.

PFAS chemicals are particularly valuable for product quality, process efficiency, and facility safety in many industries. Unfortunately, a growing body of scientific evidence points to human health consequences of exposure to these chemicals. This evidence has led to the Federal action under many regulatory platforms (i.e. TSCA, CWA, EPCRA, etc.) and development of many state-specific regulations. PFAS alternatives, such as GenX and fluorotelomer compounds, have been developed and are the subject of far fewer regulations due to insufficient evidence of adverse health effects. Trinity is keenly aware of evolving regulations on PFAS compounds and alternatives at the Federal level, and familiar with state-specific regulations via individual offices nationwide.

Facilities potentially subject to new PFAS reporting under TRI will need to know what specific processes and materials to investigate for quantifying usages and releases. Furthermore, inquiry to suppliers may be advisable to accurately determine concentrations in raw materials. The following list details some of the industries and processes that have known PFAS usage and serves as a starting point for where to look for these newly reportable compounds.

Semiconductor Manufacturing
Currently, the most common place to find the usage of PFAS chemicals is within photolithography. The chemistries of greatest concern are photoacid generators (PAGs) and top anti-reflective coatings (TARCs). PFAS alternatives have been developed for most other chemistries within photolithography and other fabrication processes, however, older procedures adopted by certain facilities may still use PFAS compounds.

Mining
PFAS compounds are particularly useful in froth flotation processes during extraction. The unique surfactant properties enhance the ability of flotation units to separate target metals. PFAS are stable in acidic solutions and are often found in the same units that would otherwise use hydrocarbon surfactants. PFAS flotation surfactants have been used in the extraction of many types of metals, so it is difficult to identify which facilities may use PFAS by the primary metals being produced.

Onsite Fire Response Teams at Large Industrial Facilities
Large petroleum refineries and terminals, chemical production facilities, and mining operations often have onsite fire response teams that use fire-fighting foam. Usage of fire-fighting foam is perhaps the most widespread source of PFAS groundwater contamination globally. Class B fluorinated types of aqueous film forming foam (AFFF) may contain PFAS in significant concentrations. Fire-fighting foams are not only used for emergency response, but also for training activities. These training activities using AFFF at industrial facilities are particularly important to account for in RY2020 TRI reporting.

Paper Products
PFAS compounds provide excellent water and grease resistance. This is particularly useful in food contact material and containerboard for boxes. Water and grease resistance chemicals may be applied in paper mills, or later during the converting process. Additionally, the use of recycled material that may contain PFAS may be considered “processing” under TRI and must be evaluated appropriately.

Other Industries
PFAS are a component in a wide variety of other processes, including:

  • Fume suppressant in chrome plating.
  • High temperature and pressure mold release coating in plastics and rubber manufacture.
  • Manufacture of composite resins, fluoroplastic coatings, and other plastics, rubbers, and waxes.
  • Injected surfactants in oil and gas wellheads.
  • Additive in some hydraulic fluids.
  • Specialty coatings with enhanced resistance to heat, water, grease, and/or chemicals.
  • Water and oil resistance in textiles, apparel, and outdoor equipment.

Adapting to New TRI Reporting Requirements

Trinity is well versed in TRI applicability determinations and proper reporting methods to ensure compliance. If you conduct any of the above processes and would like to discuss how new PFAS TRI requirements may affect your facility in 2021, or how to determine if you are using PFAS compounds, please contact your local Trinity office at 800.229.6655.