National PFAS Damage Assessment and Environmental Cost Modeling for AFFF-Impacted Sites
Project Overview
RoseyFields conducted a comprehensive environmental forensic investigation and damages assessment to evaluate the anticipated costs associated with per- and polyfluoroalkyl substances (PFAS) contamination resulting from historical use of aqueous film-forming foam (AFFF) throughout the United States. The project integrated environmental chemistry, contaminant occurrence data, public water system inventories, engineering cost models, wastewater treatment evaluations, and environmental regulatory information to develop technically supported estimates of future investigation, remediation, monitoring, and treatment costs associated with PFAS contamination.
The investigation focused on several major categories of PFAS-impacted facilities, including public drinking water systems, airports, fire training facilities, and publicly owned treatment works (POTWs). Publicly available environmental monitoring data from federal and state agencies were compiled and normalized into a unified database to evaluate PFAS occurrence, identify impacted facilities, estimate treatment requirements, and develop nationwide remediation cost projections. Engineering cost models published by the U.S. Environmental Protection Agency, together with publicly available infrastructure data and regulatory guidance, were incorporated into a quantitative framework designed to estimate long-term treatment and remediation costs under evolving PFAS regulations.
A principal objective of the investigation was to develop technically defensible methodologies capable of estimating future costs associated with PFAS contamination despite incomplete national monitoring data and rapidly evolving regulatory standards. The project therefore combined environmental forensic analysis, hydrogeology, exposure assessment, engineering economics, contaminant fate and transport, wastewater management, and geographic data processing to evaluate both current contamination and anticipated future liabilities.
Chemicals of Concern
The investigation focused on per- and polyfluoroalkyl substances commonly associated with aqueous film-forming foam releases and public drinking water contamination. Primary compounds evaluated included perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), perfluorohexane sulfonate (PFHxS), hexafluoropropylene oxide dimer acid (GenX chemicals), perfluorobutane sulfonate (PFBS), perfluorononanoic acid (PFNA), and numerous additional PFAS compounds monitored under state regulatory programs and U.S. EPA drinking water initiatives. Because environmental investigations increasingly identify complex mixtures of PFAS compounds rather than isolated contaminants, the evaluation considered contaminant occurrence across multiple environmental media, including groundwater, surface water, drinking water supplies, wastewater, biosolids, soils, sediments, and treatment residuals.
The project also evaluated contamination associated with historical AFFF use at airports, fire training facilities, and municipal wastewater treatment plants, recognizing these facilities as significant long-term sources of PFAS releases to surrounding environmental media.
Methods
RoseyFields developed a national-scale environmental database by compiling PFAS monitoring results from the U.S. Environmental Protection Agency’s Third Unregulated Contaminant Monitoring Rule (UCMR3) together with drinking water monitoring data obtained directly from numerous state environmental agencies. Individual state datasets were standardized by normalizing contaminant names, analytical units, reporting limits, sampling locations, and water system identifiers before being merged into a comprehensive database containing more than 9,000 public water systems, approximately 25,000 individual sampling locations, and over 525,000 PFAS analytical results. System characteristics, including groundwater versus surface water sources, population served, facility classifications, and infrastructure information, were incorporated using EPA’s Safe Drinking Water Information System (SDWIS).
Environmental monitoring records were then processed using relational database techniques to identify maximum PFAS concentrations for individual wells, surface water intakes, and treatment system sampling locations. Decision rules were developed to classify facilities according to groundwater or surface water source characteristics, enabling engineering cost models to be applied consistently across diverse public water systems. These methodologies produced standardized datasets suitable for estimating long-term treatment requirements and comparing contamination across multiple states.
Engineering cost estimates were developed using U.S. EPA granular activated carbon (GAC) treatment cost curves for PFAS removal from drinking water. These models incorporate both capital expenditures and long-term operation and maintenance costs as functions of treatment system capacity and water production rates. Because groundwater well flow rates were not consistently available, theoretical production capacities were estimated using population served, assumed water demand, and representative pumping rates to estimate treatment requirements for individual groundwater systems. Surface water treatment costs were similarly estimated using population-based flow calculations together with EPA treatment cost equations.
Additional analyses evaluated environmental liabilities associated with airports, fire training facilities, and municipal wastewater treatment plants. National inventories of FAA Part 139 certified airports, U.S. Fire Administration fire departments, and EPA publicly owned treatment works were integrated with published PFAS occurrence studies and Department of Defense remediation cost information to estimate investigation, cleanup, monitoring, and long-term compliance costs associated with AFFF releases and PFAS contamination.
Results
The investigation demonstrated that available environmental monitoring data already document widespread PFAS contamination affecting thousands of public drinking water systems throughout the United States, while recognizing that current contamination inventories likely represent only a portion of ultimately affected facilities. More than half a million PFAS analytical results were compiled from federal and state monitoring programs, demonstrating the extensive geographic distribution of PFAS contamination and the increasing availability of environmental data for evaluating future remediation requirements.
Application of EPA engineering cost models produced preliminary estimates indicating that treatment of known PFAS-contaminated drinking water systems would require approximately $23.8 billion in long-term treatment costs using conservative assumptions based upon currently available monitoring data. The evaluation also concluded that these estimates likely underestimate future liabilities because many states had not yet completed comprehensive PFAS monitoring, UCMR3 analytical methods included relatively high reporting limits, and future regulatory requirements are expected to identify additional contaminated systems requiring treatment.
Evaluation of airports demonstrated that historical use of AFFF for aircraft rescue and firefighting has resulted in widespread PFAS contamination of soils, groundwater, drainage systems, and surface waters at commercial aviation facilities. Based on available inventories of FAA-certified airports together with Department of Defense remediation cost data, the investigation developed preliminary nationwide estimates exceeding one billion dollars for investigation, remediation, and long-term environmental monitoring of airport facilities impacted by historical AFFF use.
A similar evaluation of municipal and regional fire training facilities found that decades of firefighting training involving uncontained AFFF releases have likely produced extensive PFAS contamination at dedicated training grounds throughout the United States. Environmental investigations conducted in several states documented PFAS concentrations substantially exceeding regulatory screening criteria, supporting nationwide estimates of approximately $1.68 billion for investigation, cleanup, monitoring, and regulatory compliance at affected fire training facilities.
The investigation also identified municipal wastewater treatment plants as an increasingly important component of future PFAS liabilities. While conventional wastewater treatment does not effectively destroy PFAS, new regulatory requirements governing wastewater discharges and biosolids management are expected to substantially increase operational costs. Review of national biosolids management practices and published economic studies indicated that restrictions on beneficial reuse of biosolids may significantly increase disposal costs for publicly owned treatment works, with preliminary nationwide estimates approaching $1.4 billion for biosolids management alone under conservative assumptions.
Conclusions
This investigation demonstrates the value of integrating environmental monitoring data, engineering design methodologies, contaminant occurrence databases, regulatory science, hydrogeology, and environmental economics to evaluate the long-term financial implications of widespread PFAS contamination. Rather than relying solely on individual site investigations, the project developed scalable methodologies capable of estimating remediation costs across thousands of contaminated facilities while incorporating evolving regulatory standards and engineering treatment requirements.
The project further demonstrates that comprehensive PFAS damage assessments require evaluation of multiple environmental exposure pathways and facility types, including public drinking water systems, airports, fire training facilities, wastewater treatment plants, groundwater resources, and biosolids management programs. As federal and state PFAS regulations continue to evolve, these integrated methodologies provide a scientifically supported framework for evaluating environmental liabilities, prioritizing remediation activities, and estimating future treatment costs.
This investigation was conducted under the direction of Dr. Paul Rosenfeld, an environmental scientist and environmental forensic expert with experience in PFAS contamination assessment, environmental damage evaluation, groundwater and drinking water investigations, wastewater treatment systems, environmental cost modeling, and regulatory analysis. Through RoseyFields LLC, Dr. Rosenfeld provides environmental forensic investigations, PFAS source characterization, contaminant fate and transport evaluations, remediation cost assessments, exposure analysis, regulatory review, and expert witness services involving firefighting foam, industrial PFAS contamination, and complex environmental litigation.
References
American Water Works Association. AWWA Briefing on PFAS. November 12, 2019.
Federal Aviation Administration. Part 139 Airport Certification Status List.
Hughes Associates, Inc. Estimated Quantities of Aqueous Film Forming Foam (AFFF) in the United States. Prepared for the Fire Fighting Foam Coalition. August 2004.
U.S. Environmental Protection Agency. Per- and Polyfluoroalkyl Substances (PFAS): Source/Site Characterization and Treatment/Remediation.
U.S. Environmental Protection Agency. Safe Drinking Water Information System (SDWIS).
U.S. Environmental Protection Agency. Third Unregulated Contaminant Monitoring Rule (UCMR3).
U.S. Department of Defense. Aqueous Film Forming Foam Report to Congress. October 2017.
CDM Smith. Cost Analysis of the Impacts on Municipal Utilities and Biosolids Management to Address PFAS Contamination. October 2020.