Shamrock, a Newark, New Jersey-based Teflon recycling company, makes lubricant additives and other micropowders out of its process. By-products of the process include chemicals in the category of perfluoroalkyl and polyfluoroalkyl substances, commonly referred to as PFAS.

In December of 2018, the company self-reported a leak from underground storage tanks intended to hold water from scrubbers at its production site in Henderson, Kentucky. The water contained PFAS, and the company had discovered that three of the tanks had leaked. Those tanks have been removed and replaced with above-ground tanks.

PFAS have been dubbed forever chemicals because they do not break down naturally. According to a PFAS awareness page on Shamrock’s website, the American Chemical Society says “5,000 to 7,000 chemicals are categorized as PFAS.”

Two key chemicals in the PFAS family are perfluorooctanoic acid, or PFOA, and perfluorooctane sulfonate, or PFOS. Those two compounds have been replaced with other PFAS in manufacturing but still were the most widely used and studied before they were phased out.

PFAS are found in everyday consumer, commercial and industrial products, including shampoo, cosmetics, fast food wrappers, clothing and fire extinguishing foam. Because they do not degrade, once entering the environment they persist there, and scientists say they are commonly found now in water, air, fish and soil.

The EPA says peer-reviewed scientific studies have shown that exposure to sufficient levels of PFAS may lead to birth defects, cancer and harm to the liver, the immune system and the thyroid, among other effects. The U.S. Department of Health and Human Services’ National Toxicology Program reviewed 33 human studies, 93 animal studies and 27 in vitro or mechanistic studies on the effects of PFOA and POFS and presumed both are a hazard to humans.

However, PFAS are not yet regulated by the EPA, though the agency has set a lifetime exposure advisory of just 70 particles of PFAS per trillion particles of drinking water.

The agency has published a roadmap of research and regulations it plans to propose. One of its aims is to monitor levels of PFAS in drinking water. EPA also called for research into scientific approaches to clean up these chemicals. In January, the agency added four PFAS chemicals to its Toxics Release Inventory, which requires manufacturers to report how much of each chemical is emitted into air and water or placed in landfills.

In October of last year, New Mexico Governor Michelle Lujan Grisham submitted a petition requesting PFAS to be identified as hazardous waste under the Resource Conservation and Recovery Act. In response, the EPA said it would initiate the process to add four PFAS chemicals to its list of RCRA Hazardous Constituents, which would lead to the chemicals being subject to “corrective action requirements.” The agency said it would also look to require investigation and cleanup for PFAS waste.

“These actions build on EPA’s broader strategy to comprehensively address PFAS pollution across the country, following its announcement last week of the PFAS Strategic Roadmap,” the agency said after the petition was submitted.

Lujan Grisham said PFAS spills from the state’s Cannon and Holloman Air Force bases have contaminated dairy farms and Lake Holloman, which recorded PFOA levels as high as 5,900,000 parts per trillion, more than 84,000 times the EPA’s health advisory limit.

In 2019, a 40,000-gallon spill of firefighting foam leaked from a Connecticut airport into a nearby river. Two years later, the state began cleaning up the pollution. A similar situation occurred in Michigan, when a 200-gallon firefighting foam spill at the Kalamazoo-Battle Creek International Airport led to high PFOS levels at a nearby wastewater treatment plant.

In Henderson, government agencies are running tests – called characterizations – on samples taken from soil and water surrounding the Shamrock facilities. A creek near the site feeds into the Ohio River.

In 2019, a sample taken from one of six wells within a one-mile radius of one site found 5.1 parts per trillion, on par with the 5 to 7 parts per trillion found in a raw sample from the Ohio River, said Shamrock Director of Manufacturing Mike Jussila. According to Shamrock, those wells are test wells and not used for drinking water.

“Extensive testing has found no instances of PFAS exceeding this level in municipal drinking water or private drinking-water wells,” Shamrock said on its website. “In fact, when the Kentucky [Department of Environmental Protection] tested levels of PFAS in the Ohio River in 2019, levels were higher in some places upstream from Henderson than they were in Henderson – although even these levels were very low.”

Henderson’s city council formed a working group to develop a strategy for dealing with a large area of groundwater under and near the town where high levels of PFAS have been detected. According to The Gleaner, a Henderson news outlet, Kentucky DEP Commissioner Tony Hatton said at the committee’s initial meeting in November of last year, “I’m firmly convinced that the levels we see in the finished drinking water are not the result of releases of PFAS from the Shamrock facilities. Shamrock has been responsive of what we’ve asked them to do.”

However, a test at one of Shamrock’s compounds in 2019 found 345 million parts per trillion in its groundwater, according to local news affiliate WFPL, which said it obtained the information through a state records request. The outlet also said Shamrock hired a consulting firm which found PFAS chemicals in the area surrounding its three sites, including in residential and commercial areas, shortly after Shamrock discovered the PFAS in its underground tanks.

Shamrock did not respond to multiple requests for comment from Lube Report.

Smokestacks were also inspected for possible contamination by air. At a February Henderson PFAS working group meeting, Jussila said that presents another challenge. “The EPA has a roadmap out but it’s all geared toward water, there’s nothing geared towards air. We are operating in uncharted territory,” he said at the meeting, a recording of which was posted by Henderson on YouTube.

In 2020 the European Commission indicated current laws didn’t go far enough in regulating PFAS. There are some state regulations in the U.S. with varying standards for maximum contaminant levels of various PFAS in drinking water, though most have not adopted such laws, according to data posted by the EPA.

Earlier this year, the EPA added four PFAS compounds to its Toxics Release Inventory, which tracks information submitted by facilities on chemicals that may cause harm to human health or the environment. Those chemicals are:

• Perfluorobutane sulfonic acid
• Potassium perfluorobutane sulfonate
• Perfluorobutanesulfonate
• 2-Propenoic acid, 2-methyl-, hexadecyl ester, polymers with 2-hydroxyethyl methacrylate, .gamma.-.omega.-perfluoro-C10-6-alkyl acrylate and stearyl methacrylate

Because they’ve been added to the TRI, facilities must report how much of these chemicals are released into the environment or dealt with through recycling, energy recovery and treatment.

According to Shamrock’s website, the company entered an Agreed Order with the Kentucky DEP to determine the extent of contamination and then clean up the pollution.

Donna Stinnett, a spokesperson for Henderson, said the state EPA is still doing what it calls off-site characterization testing. “We haven’t seen the detailed results of that yet,” she told Lube Report, though they have seen the agency’s initial testing reports.

“The things that have been done so far, Shamrock self-reported them to the state EPA to get a procedure underway for them to work through this process of what will be the next steps, and if at some point in time in the future the federal EPA comes down with a little bit more specific guidelines, how to deal with it,” she continued. Stinnett said the state and Shamrock have a “good working relationship.”

The next PFAS working group meeting will take place mid-summer at a date to be announced, according to the city of Henderson’s website.