Dave Ross and Anna Wildeman provide a perspective of how state and local governments are dealing with the emerging regulatory framework for PFAS.
Dave and Anna kick off a PFAS podcast series taped on location at the Missouri Water Seminar to provide an on-the-ground perspective of how state and local governments are dealing with the emerging regulatory framework for PFAS. Our first guest — Water Program Director Chris Wieberg of the Missouri Department of Natural Resources — explains how the "Show-Me" state uses data collection, collaboration, and risk communication to advance PFAS regulatory and management efforts statewide.
Reflections on Water, S01 Ep06, “PFAS in Focus: Show-Me Insights From Chris Wieberg, Missouri Department of Natural Resources”
Recorded August 2022
Dave Ross (00:02):
Welcome to Reflections on Water. I'm Dave Ross.
Anna Wildeman (00:05):
And I'm Anna Wildeman. Welcome back from summer vacation. Dave, it's been a while since we recorded podcast here, but I guess we're going back to school like everybody else.
Dave Ross (00:15):
Yeah, it has been a nice summer break. My kids are off to school tomorrow, and so I think it's time that you and I spend a little more time in the studio and record some podcasts, Anna.
Anna Wildeman (00:24):
Yeah, I'm pretty excited about what we have today. Over the summer, we took a trip out to Missouri. We attended the Missouri Water Seminar, and we had a chance to talk to three individuals about something that I feel like everybody's talking about, and that is PFAS, and so we have a really cool series of three interviews with some folks local in Missouri who are going to share their perspective on EPA's recent health advisories.
Dave Ross (00:50):
Yeah, the three perspectives we have are from the private sector, from local government, and state government, and I think it's appropriate that we start the first podcast with the state perspective, and so we talked to Chris Wieberg who runs the water program for the Missouri DNR and he gives us a really great high-level overview of what the state of Missouri is doing to grapple with the emerging contaminant PFAS in water and wastewater and what the state is doing in reaction to and in coordination with the federal government, so it's a great interview.
Anna Wildeman (01:22):
Yeah, I agree. Let's roll the tape. So, here we are. We're in Columbia, Missouri at the Missouri Water Seminar 2022, and we're here with Chris Wieberg, director of the Water Protection Program at the Missouri Department of Natural Resources. Chris, welcome to the podcast.
Chris Wieberg (01:44):
Happy to be here, Anna. It's good to have you guys in Columbia, Missouri, home of the University of Missouri, MU Tigers. Happy to have you here.
Anna Wildeman (01:52):
Great. It's good to see you.
Dave Ross (01:54):
Hey, Chris. I caught your talk this morning, the high level overview of things that are happening in the water space here in Missouri. Thought it was a great talk. I wanted to follow up on this podcast on one of the topics that you addressed to the crowd that I thought is it's the topic of the day, PFAS, and you gave a really nice overview of what is happening here in the state. Could you give us your perspective what you're working on, particularly from the water perspective here in state Missouri?
Chris Wieberg (02:22):
The water program at Missouri DNR is made up of two branches, one being the drinking water branch and the other being the clean water branch and PFAS is one of those pollutants that is going to and is impacting our work in both sectors. Right now, as it relates to the state, we're focused in a couple areas. One, trying to get a handle on what we don't know about PFAS as it relates to our drinking water systems, and so we've done a fair amount of monitoring over the years through our unregulated contaminant monitoring rule, UCMR 3, and we're gearing up for UCMR 5, which will also include monitoring for PFAS.
Chris Wieberg (03:00):
In-between those two efforts, we also contracted with the University of Missouri Science and Technology, the Rolla campus to do additional targeted PFAS monitoring, all of which were conducted and will be conducted at the minimum detection levels of the day, so we're struggling with, and working with a lot of different data quality challenges. Moving forward, we're also utilizing some federal funding to do additional sampling of public water supplies that would fall below the UCMR levels to get a better understanding of what public water supplies are seeing as it relates to concentrations of PFAS. All of those sampling efforts are things that we're doing on the drinking water side.
Chris Wieberg (03:44):
On the clean water side, we're working towards us setting up a sampling program or a monitoring program for wastewater and stormwater, both on the influent side and the affluent side, as well as sampling and doing analysis for a biosolid. Broadly across the state, doing things that would allow us to get a better idea and a better understanding of what we're finding as it relates to PFAS across the state of Missouri in the water space.
Dave Ross (04:14):
I'm going to ask the follow-up on the sampling on the drinking water side and then I want to touch base a little bit on the wastewater side. Getting all this data, what are you going to do with this data? What is the state's plans? Once you have the data in, what's the action on it?
Chris Wieberg (04:28):
Just really getting an understanding and inventory of the data, and then also taking that data and using it to inform the public about what they can expect as it relates to their water supply. We've seen the advent of new lower health advisory levels from EPA, and so implications as it relates to notifying customers as it relates to the quality of their water would be something that we would expect to see. We anticipate being able to utilize consumer confidence reports as a means for public water supplies to make those notifications.
Chris Wieberg (05:00):
On the clean water side, really understanding what concentrations we're finding in wastewater as well as biosolids will be key in understanding what the future implications would be for any sort of federal action on the side of establishing water quality criteria or establishing any sort of permit requirements that would be of something that point sources would see down the road.
Anna Wildeman (05:27):
Great segue, Chris. The next question, which is really an important one, because one of the big challenges with PFAS is that the states and the federal government all seem to be moving at different speeds state to state, and of course, the group of states compared to the federal government, so we're seeing this potential for a regulatory patchwork and conflicting regulations. You just talked about the potential for permit limits and discharge limits and things like that, so what are you seeing in that space? Are there operators across state lines between here and your neighbors that are facing those kinds of challenges? Or do you see them coming?
Chris Wieberg (06:06):
Yeah, so folks in the water sector are very connected to what's going on in other states within the region, but also just nationally, hearing and reading news articles about certain regulatory approaches being established in various states, whether that be on the statutory side, or seeing voluntary mechanisms and approaches. Those things are concerning the point sources in Missouri in a variety of ways that patchwork leads to an unknowing or uneasiness as it relates to predictability, as it relates to what my next move is going to be as a utility. For example, one such example, or question that I've gotten is, "What would happen if a state adjacent to Missouri banned the usage of or land application of biosolids? Would we expect to see biosolids coming into Missouri that we would have to address? What are you going to do if that material has PFAS concentrations at levels that would be concern?" Really, grappling with those new questions these new problems that we haven't had to address in the past is something that we're seeing an uptick in.
Chris Wieberg (07:16):
Additionally, Missouri is the number two cattle-producing state in the country and stories and issues that result from PFAS contamination of the landscape that have led impacts in the agricultural sectors also play heavy on what we do as a state moving forward as we establish whatever public policy we establish for this pollutant. It plays on a lot of different sectors and it impacts a lot of different individuals across the state, and so really, figuring out what that needs to look like is important to the state of Missouri. We are the Show Me State, so our decisions will be based on data and information that we collect, and it's almost a demand of our stakeholders that we do and approach this issue that way.
Anna Wildeman (08:01):
Are you doing any work with your neighboring states? Any coordination, any debt collection across those state boundaries to understand what might be coming in, or where it might be going?
Chris Wieberg (08:12):
We are part of the Upper Mississippi River Basin Association, so we're one of the five states, the southernmost state, the one state with the accent in the group, but we've coordinated with some monitoring efforts on the Mississippi River of which did include some monitoring of PFAS in drinking waters at intakes up and down the river, as well as we have done some fish tissue work with UMRBA and the other states in the basin. That's just one example.
Chris Wieberg (08:38):
We also have various coordination, meetings, and discussions with our states that are in Region 7. We always look towards our neighboring states as to what things are going on in Iowa and Kansas and Nebraska that may be analogous to what we're seeing in Missouri, or not, and how does that impact the way we approach our programs in development of our programs?
Chris Wieberg (08:59):
Missouri is unique in that we have no tribal land. Those issues that come from that EPA interaction with regard to the tribes is not something that we have to deal with so much in Missouri. That being said, we do have some tribal lands in Region 7, and so how standards are approached in those other states do make a difference to Missouri because some of those waters are upstream waters of Missouri, and so figuring out how that is approached is important to us, so there's various activities that are coordinated with other states or associations or organizations that lead to consistent approach, if you will, or as consistent as we can manage as it relates to any sort of regulatory program.
Chris Wieberg (09:38):
I will say, though, every state is unique and has its own challenges as it relates to whether you're developing water quality standards or approaching a drinking water situation, and each state has different drivers, if you will, and what works in Iowa doesn't always work in Missouri, and so on and so forth, so expect there to be differences, but to the extent that we can coordinate and approach it consistently, that's our goal.
Dave Ross (10:04):
On the coordination piece with EPA, the federal government, have you been having proactive conversations with the regional office or EPA headquarters? There's a lot of money coming out. There're billions of dollars that they're going to come into the emerging contaminant for PFAS cleanup in the water sector. Where are you at in the relationship with EPA on PFAS?
Chris Wieberg (10:24):
Sure. The EPA regions as well as headquarters are definitely hyper-focused on getting bill money out to the states to address some of these challenges, emerging contaminant grants for the SRF, or emerging contaminant grants for small and disadvantaged communities are available to states. My thought on that right now is that the states have so many competing interest as it relates to their time and work and more grants on top of more grants make it even more challenging for the states to administer. We are dealing with real resource problems and I think those are acknowledged by the EPA regions and EPA headquarters folks, but at the same time, their objective is to get the money out there.
Chris Wieberg (11:07):
We've put the money out there and the solicitations out there to obtain some projects to further utilize emerging contaminant monies, although these early years of those grants are seeing very few applicants that are really moving forward with projects to address emerging contaminants like PFAS, mainly because they don't know they have a problem yet potentially, and so as this problem identification phase moves through the state, we would expect to see more projects, but early adoption of granulated activated carbon, or some sort of reverse osmosis on drinking water system won't be in the cards for at least the next couple years from Missouri, just because we don't have applications raring to go at this point in time.
Chris Wieberg (11:46):
Additionally, that puts us in a awkward position where there are other grants that come available, so we've got $13 million in our hands right now for emerging contaminants. We've got one project that's lying in the wings. EPA's going to meet with us next week to talk about a small disadvantaged community grant for emerging contaminants. We're going to be evaluating whether or not that makes sense for the state, but when you're sitting on X million of dollars for a problem, and there's this other money that is potential for that, but you're not able to spend it, it may not be in our best interest to tie up those dollars in Missouri, unfortunately. That's an awkward position for the state to be in because we want to get this money out to solve problems, we just don't know what our problems are yet, and so the speed at which the grant money's coming is a little bit troubling.
Dave Ross (12:36):
You mentioned earlier the new health advisory came out, the interim health advisories for PFO and PFAS and the final health advisories for GenX and PFBS. Do you think the new health advisories will accelerate the need or the infrastructure pipeline as people begin to go out and sampling the earlier UCMR 3, you may have data out there that was a non-detector of not at the 70 parts for trillion in the past, but suddenly it is now, do you see that as an accelerant?
Chris Wieberg (13:07):
I do see it as an accelerant. I do, though, see that resources will limit our ability to stand up widespread sampling programs that cover the whole universe in a quick fashion, so you're still talking about a two-to-three-year program for sampling the public water supplies in the state of Missouri. We currently have 2,700 public water supplies in the state of Missouri. We won't be sampling all of those because some of them are very small transient-type systems, but the ones that are community systems, we intend to get through all of those and sample all of those over the next two years, and then have UCMR 5 on top of that, but you're still talking about a three-year monitoring program.
Chris Wieberg (13:48):
You'll see some early projects available themselves where we do have health advisories where the public does demand that a public water supply address this problem and the opportunity through the SRF or the opportunity through other emerging contaminant grants will lend itself to an infrastructure project, but until you have a problem, it becomes quite difficult to address that problem. I think the situations exist, it's just you will have to have the data to move the needle to that next step.
Anna Wildeman (14:16):
So, with that backdrop and knowing that you are in the middle of this huge data collection exercise, how is the state dealing with a risk communication element? In other words, how do you talk about whether your communities might be at risk or not based on the new health advisory level?
Chris Wieberg (14:38):
So, let me start off by saying I think our position will always be to over-communicate the situation or an issue as it relates to PFO, PFAS, or health pollution issues that address or impact public health. We intend to over-communicate that information out to the public and deal with that as it may come. That being said, utilizing some of our tools with regard to GIS, so geographically showing or demonstrating where certain water supplies have had detections, or where certain water supplies have had levels that are higher than the health advisory, or subject to the health advisory would be one thing that we seek to do. We also have put out some action plan information or FAQ information on our website to help express and communicate concerns with pollutant of concern.
Chris Wieberg (15:26):
I think our public demands that we be open and forthcoming with the information and it's our intent to be forthcoming with the information that the double-edged sword or the other side of the coin is making sure that information and that communication is such that it's clear and that there aren't any unintended consequences or issues that rise to the level of concern where there need not be concerned and what would the unintended impact be to a public water supplier, or to a city, or an industry that's adjacent to, or a military installation where potentially the problem isn't that, but maybe it's just contamination of a sample unintentionally through the sampling process, making sure that information is clear when it's out there so that you don't have any casualties or unintended casualties of the communication. That weighs heavy on our minds, but at the same time, that risk-versus-reward conversation always ends up where we're in a place where we're going to over-communicate an issue just to make sure that everybody knows what's going on.
Dave Ross (16:30):
Earlier, you mentioned each state maybe approaching PFAS issues slightly differently. Early on this discussion, you mentioned the consumer confidence reports. These are health advisories, but yet thinking about creatively on how to use existing communication tools like the consumer confidence reports, have you had conversations with EPA, "You may be creating a framework that our states might be interested in"?
Chris Wieberg (16:52):
Yeah, that's a good question. Early on, when we got the draft revised health advisories, we stepped back and wondered to ourself, "How are we going to work with communication with our local public health agencies and the Department of Health and Senior Services with regard to this information? How are we going to have that communication with the public water supplies and the event that there needs to be some sort of notification under the health advisory and how does that work? Is it something separate than a consumer confidence report? Is it a special notice, a special public notice? How does that look?"
Chris Wieberg (17:23):
We met with EPA Region 7 and asked those questions and we're happy to hear from Region 7 that they felt that the consumer confidence report is an adequate mechanism to inform the public about the quality of the water that they're getting from their public water supply. As I mentioned, double-edged sword, consumer confidence report only comes out at a very limited frequency and we are sensitive to the fact that some of the public may not tune in, or catch that bit of information, and find that it's not adequately expressed to the public at large.
Chris Wieberg (17:56):
I think in those situations, we're going to have to work with the public water supplier on some sort of risk communication plan to help express to their customers what the situation is, whether it's something that you need to be concerned about or not, and what the appropriate next step would be, whether that's evaluation of some sort of barrier technology like reverse osmosis, or granulated-activated carbon, or do we need to do more analysis and sampling? Do we need to figure out why we're having a problem? Do we maybe need to look for an alternative water source to blend and then deal with that issue in these mechanisms? These are conversations that largely will end up being quite protracted and longer and figuring out what that needs to look like will be important next steps, but at that time that it avails itself will be when we have that conversation with the water system.
Anna Wildeman (18:46):
It sounds to me like you guys are grappling with all of the issues that I think communities and states and leaders are grappling with across the country and it sounds like we're going to be seeing a lot more from the Missouri DNR as the data is collected and as work to get some of those materials out into the public for consideration and consumption. Chris, you've been extremely generous with your time today. We won't tell anybody that you stuck out so quickly back down there. We know you have an important role here at this conference, so we appreciate the time.
Chris Wieberg (19:19):
Thank you. Appreciate it. Happy to do it.
Dave Ross (19:22):
Yeah, thanks for joining us, Chris.
Chris Wieberg (19:24):
Happy to be here. Thanks.
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