PFAS risks Environmental and liability issues explained conclusively

PFAS risks Environmental and liability issues explained conclusively

Discharge into the PFAS wastewater network

At the end of 2006, the Ministry of the Environment, Nature Conservation, Agriculture and Consumer Protection of North Rhine-Westphalia ordered a state-wide inspection of all wastewater discharges from municipal sewage treatment plants with more than 2000 inhabitants for PFOA and PFOS. The orientation value of 0.3 µg/l (sum of PFOA+PFOS) or 1.0 µg/l (sum of all 14 PFAS measured), which is not directly legally binding, was set as the limit value. If this value was exceeded, the causes were investigated in detail and countermeasures were introduced in consultation with both the operators of municipal wastewater treatment plants and the operators of industrial wastewater treatment plants. The aim of these official requirements was to prevent PFAS from entering the raw water used for drinking water production.

Measures to reduce or avoid PFAS emissions were taken at a large number of industrial direct and indirect dischargers. This included the substitution of problematic substances, the use of special cleaning techniques, organizational measures and the optimization of production processes. Technical solutions for wastewater treatment were implemented, including activated carbon treatment stages and ion exchange plants, particularly in areas such as electroplating, plastic electroplating, surface finishing and metal processing.

In North Rhine-Westphalia, industries such as electroplating, plastic electroplating, surface finishing, metal processing and the use of PFAS-containing extinguishing agents are particularly responsible for temporarily high PFOS emissions from wastewater treatment plants. The emissions also originate from specialty chemicals, hydraulic fluids and can occur as impurities from fluorocarbon resin coatings on various products.

H4PFOS and perfluorobutane sulfonic acid (PFBS) have gained importance as substitutes for PFOS, but they are just as difficult to degrade and require considerable effort to remove from raw water.

Years after the start of the investigations and after continuous expansion of the monitoring criteria, including the inclusion of substitute substances such as H4PFOS, the number of wastewater treatment plants and landfills with exceedances has been significantly reduced. Nevertheless, ongoing monitoring is still carried out at individual plants (as of 2023).

Beware of incorrect cleaning recommendations on the internet

It is vital that companies and plant operators have access to reliable and scientifically sound information when it comes to PFAS decontamination. The internet is full of different recommendations and advice on cleaning, but not all of them are technically correct or suitable to meet the complex requirements of PFAS decontamination. It is advisable to rely on recognized experts and professionals who have the necessary expertise and experience to carry out decontamination effectively and safely.

Caution when discharging PFAS-containing wastewater into the sewer system without prior qualitative testing of the wastewater

The discharge of PFAS into the sewage system without prior qualitative testing of the wastewater can have serious environmental impacts and legal consequences. It is extremely important that plant operators ensure that they know the composition of their wastewater, especially with regard to PFAS. This requires a comprehensive analysis to ensure that the discharge complies with applicable regulations and standards. Improper discharge of PFAS can not only pollute the environment, but can also result in significant liability risks.

Caution with liability exclusions by subcontractors and cleaning companies

Special care must be taken when hiring cleaning companies or subcontractors for PFAS decontamination. It is important to carefully review contract terms and disclaimers. Some companies may offer cleaning services but accept no liability for the results or environmental impact of their work. In such cases, the responsibility often lies solely with the plant operator.
NT Service GmbH takes a transparent and responsible approach here. Through explicit agreements within the framework of commissioning contracts, they not only provide the service, but also assume full liability for the quality of the work and the impact on the environment. This is an important step to ensure that the decontamination is carried out properly and that all relevant liability issues are clarified.

The responsibility of the system operator

In principle, the responsibility for proper PFAS decontamination and compliance with the applicable environmental regulations lies with the plant operator. It is his duty to ensure that all necessary steps are taken to minimize PFAS emissions and to carry out the cleaning measures professionally. This includes the selection of trustworthy cleaning companies and subcontractors with proven expertise and experience.

The responsibility and product and environmental liability of NT Service GmbH

NT Service GmbH is an example of a company that assumes full product and environmental liability for the services they provide. This means that they are not only responsible for the successful completion of PFAS decontamination, but also for the environmental impact and regulatory compliance.

Such companies go the extra mile to ensure that their customers are protected and do not have to bear unexpected liability risks. This is an important safeguard that ensures decontamination is done effectively, safely and in an environmentally friendly manner.

Overall, it is vital that companies and plant operators exercise extreme caution during PFAS decontamination, engage qualified professionals and establish clear agreements to ensure that all relevant aspects of liability and responsibility are clarified. Only through such comprehensive measures can it be ensured that PFAS decontamination is carried out successfully and without negative consequences for the environment.

Regular monitoring and compliance

PFAS decontamination requires not only careful implementation, but also continuous monitoring and compliance with environmental regulations. Plant operators should ensure that they regularly monitor the quality of the discharged wastewater and ensure that PFAS emissions are below the legal limits. This is crucial to minimize environmental impact and prevent legal consequences.

Communication and transparency

Open communication between all parties involved is crucial. Plant operators should work closely with contracted companies and subcontractors to ensure that all requirements and responsibilities are clearly understood. NT Service GmbH serves here as an example of a company that relies on transparency and clear agreements to share responsibility.

Ongoing training and further education

PFAS decontamination is an evolving field and it is important that all stakeholders are aware of the latest developments and best practices. Plant operators should ensure that their staff and partners are regularly trained and up to date with the latest techniques to ensure that decontamination is carried out effectively and safely.

Summary

PFAS decontamination is a complex task that requires not only expertise, but also clear agreements, monitoring and communication between the parties involved. Plant operators should carefully consider who they work with and ensure that they take full responsibility and liability for the implementation and environmental impact of decontamination. This is the only way to ensure that PFAS decontamination is carried out effectively and safely and that all applicable regulations and standards are met.

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