Report chemical constituents for forensic PFAS source identification –WWALS to U.S. EPA 2021-09-27

We requested much more labeling of chemical constituents of PFAS “forever chemicals”, to enable tracking PFAS contamination to its sources, when U.S. EPA held a public comment period about a PFAS rule.

The Atlanta Journal-Constitution brought this problem to our attention back in 2018, due to PFAS contamination from all three Air Force bases in Georgia, plus it turns out the Florida Fire College in Ocala. There are probably many more sources, including biosolids dried out from human wastes and used as fertilizer.

[Map, Letter]
Map, Letter

WWALS letter to EPA

See also the PDF.

The WWALS letter references a St. Johns Riverkeeper letter, co-signed by Waterkeepers Florida (including Suwannee Riverkeeper). PDF.


September 27, 2021


Michal Freedhoff

Assistant Administrator

Office of Chemical Safety and Pollution Prevention

Environmental Protection Agency

1200 Pennsylvania Ave. NW

Washington DC 20460-0001


Stephanie Griffin

Data Gathering and Analysis Division

Office of Pollution Prevention and Toxics

(202) 564-1463

Re: Report as many chemical constituents as possible for forensic PFAS source identification; TSCA 8(a) PFAS Data Call EPA-HQ-OPPT-2020-0549

We write to thank EPA for and to provide recommendations in the Reporting and Recordkeeping for Perfluoroalkyl and Polyfluoroalkyl Substances under Section 8(a) of the Toxic Substances Control Act (TSCA), docket number EPA-HQ-OPPT-2020-0549 .

In order to identify upstream sources of PFAS contamination, we recommend requiring identification of as many constituents of PFAS chemicals as possible. First we present our recommendation, followed by some potential uses as motivation.


  1. PFAS are highly complex mixtures of closely related compounds. Little is known about the toxicity of most constituents thus a conservative approach to evaluating the potential health impacts of PFAS requires that they be treated as a chemical class with toxicity of each constituent considered equal. This can be refined as more is learned about toxicity of individual PFAS compounds.
  2. To contribute to refining toxicity estimates of PFAS mixtures manufacturers of PFAS should at minimum be required to report the detailed chemical composition of their products with as many constituents as possible separated and specifically identified. Once the toxicity of more of the PFAS compounds are established it may be possible to consider a weighted approach to toxicity assessment of PFAS mixtures as is done with other chemical  families such as the chlorinated dibenzodioxins.
  3. Knowledge of the chemical composition of PFAS can also be used forensically and aid in identifying the sources of PFAS in environmental samples. This can be achieved by direct comparison of the PFAS compound profile in the samples to a library of PFAS product composition reported to EPA under TSCA.

The City of Ocala, Florida, already voluntarily tests for half a dozen such substances: [1]  

We voluntarily monitor for Per and Polyfluoroalkyl substances (PFAS) annually and have included the results above. The EPA sets a Health Advisory Level (HAL) of 70 ng/L for PFOS and PFOA. Results in the Level Detected column are the highest detected level at the point of entry.

Our water system has sampled for a series of unregulated contaminants. Unregulated contaminants are those that don’t yet have a drinking water standard set by EPA. The purpose of monitoring for these contaminants is to help EPA decide whether the contaminants should have a standard.

We agree with the City of Ocala that the EPA should set standards for those six and other PFAS contaminants. We further recommend that EPA require manufacturers to report detailed chemical constituents of their products so that such test results can be used to identify sources of contaminants.

[Potential Sources]
Potential Sources

Potential Sources

In the Suwannee River Basin and nearby in Georgia and Florida, known sources of PFAS contamination include firefighting facilities, military bases, and biosolids from human waste.

  1. The  Florida State Fire College of Ocala, Florida, has been known since 2018 as the source of PFAS contamination in local water wells. [2]  Measures to deal with this problem have included extensive water well sampling and provision of replacement drinking water sources for contaminated wells. Marion County, Florida, is now seeking federal funding to extend drinking water lines to the affected area. [3]
  2. All three Air Force Bases in Georgia, including Moody Air Force Base near Valdosta, in the Suwannee River Basin, concluded from their own research in 2016 that their firefighting PFAS chemicals had contaminated local groundwater and streams. [4]  Yet none of them tested private wells to see whether contamination had reached those. We later learned that there is funding available from the U.S. Department of Defense for Air Force Bases to do such private water well testing. [5]  Several military bases in Florida also have reported contamination, including Jacksonville Naval Air Station. [6]  Presumably military bases use specific known PFAS products.  If owners of private wells do such testing themselves and find PFAS contamination, it would be most useful to know detailed chemical compositions of the various firefighting chemicals to determine which, if any, were the source.
  3. Biosolids from human wastes are shipped north from Miami and other cities to numerous locations, such as Jacksonville. [7]  PFAS contamination in such biosolids may come from a variety of sources, but with detailed chemical compositions of known products, it may be possible to determine which products were the contamination sources for biosolids from specific cities. That in turn could enable determining from proportions of PFAS chemicals detected in water wells which city they came from. It is not clear that anyone knows all the destinations of those biosolids. When they are used as fertilizers, some of these biosolids will run off into waterways or leach through the ground into groundwater and the Floridan Aquifer.

There are numerous firefighting departments and training facilities that drain to the Alapaha, Withlacoochee, Santa Fe, Suwannee, and other Rivers in the Suwannee River Basin, in addition to Moody Air Force Base. Because of the porous nature of the underlying limestone rock of the entire region, and the numerous subterranean conduits of the Floridan Aquifer and the other aquifers above it, PFAS contamination can be carried in any direction from a contamination source, coming up in water wells, springs, or rivers.

Thus detailed knowledge of the chemical composition of PFAS products would help determine which, if any, of the above three types of sources were the origin of detected contamination, and perhaps even to pinpoint specific sources.

We thank you for your consideration of this recommendation for detailed PFAS product compositions.

John S. Quarterman



WWALS Watershed Coalition, Inc.

Dr. Thomas Potter


WWALS Science Committee Chair

[1]   City of Ocala, Florida, PWS-ID # 342-0922, 2020 Water Quality Report,

[2]   Florida Department of Environmental Protection, Division of Waste Management , Waste Cleanup Program , “Florida State Fire College,”

[3]   Danielle Johnson , Ocala Star-Banner, April 10, 2021, “Marion County seeks federal funds to provide Lowell area with central water,”

[4]   Meris Lutz, The Atlanta Journal-Constitution, January 3, 2019, “Contaminated groundwater, a toxic legacy of Georgia’s air bases,”  

[5]   Maureen Sullivan, Deputy Assistant Secretary of Defense (Environment, Safety & Occupational Health), March 2018, “Addressing Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA),”  

[6]   EWG, January 6, 2021, “PFAS Contamination in the U.S.,”

[7]   Jason Garcia , Florida Trend, November 28, 2018, “Biosolids: Waste to fertilizer to – pollution? One region's waste fertilizes another region's pastures — but becomes a source of pollution in the process.”–pollution

[PFAS Contamination in the U.S. (October 4, 2021) --EWG]
PFAS Contamination in the U.S. (October 4, 2021) –EWG

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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