One of the growing threats to our watershed is toxic pollution from PFAS, also known as “forever chemicals” and one of our best tools to fight further degradation is regulation. The Clean Water Act provides many powerful regulatory tools that can stop PFAS pollution at the source, before it ends up in our drinking water, on our dinner plates, or in the river where we swim and play.
Two Tracks of Protection: Surface Water and Drinking Water
PFAS (per- and polyfluoroalkyl substances) in our water are regulated in two primary ways. The Clean Water Act controls pollution going into rivers, lakes, and other surface waters, while the Safe Drinking Water Act ensures the safety of our public tap water (note: the Safe Drinking Water Act does not regulate private wells and only applies to municipal systems). Most people are more familiar with drinking water standards, but surface water standards are just as (if not more) important, because they help prevent PFAS from entering our waterways in the first place.
While the Clean Water Act is not designed specifically for groundwater or drinking water protection, its focus on improving surface water quality and regulating activities that can affect water flow helps safeguard groundwater resources indirectly. In simple terms, under the Clean Water Act, water quality standards set the "rules" for how clean water must be. Permits make sure that industries and businesses follow those rules when they release water into the environment, by setting effluent limits, or "rules" for how clean the water discharged from a facility must be to meet those standards. These permit rules extend far beyond the pipes going directly into the river. This permit system includes industrial sites off the river where stormwater runoff could also impact surface water through the municipal stormwater systems.
In Spokane, protecting surface water also protects drinking water—because our river and aquifer are connected. In “losing reaches” of the river, the Spokane River recharges the aquifer. In “gaining reaches,” the aquifer feeds the river. That means pollution in the river doesn’t just stay in the river—it can travel underground, and eventually end up in the water we drink. If we can stop PFAS at the source, it won’t have a chance to reach our drinking water. That’s where surface water regulation becomes a powerful prevention tool.
The difference between drinking water and surface water standards for PFAS is staggering. The standards are so far apart they do not even use the same unit of measure. The surface water standard for PFOS is 8.4 µg/L (or parts per billion), while the drinking water standard is 4 ppt (parts per trillion)—making drinking water standards over 2,000 times more protective (Learn more: What are parts per million, billion and trillion?).
Similarly, previous recommendations from the Washington Department of Health say you should not eat fish with tissue concentration over 28.2 µg/kg (Christie, 2022), whereas the water quality standard for fish tissue contamination is a staggering 6.75 mg/kg, 239 times higher. The existing standards are not protective enough to ensure the health of our river for future generations.
Where PFAS Enters Our River – And Where Does it Go
There are many regulated sources of PFAS pollution in our watershed. These include wastewater treatment plants, industrial facilities, urban and industrial stormwater runoff, and agricultural runoff—especially where biosolids or PFAS-laced pesticides are used. These sources all have existing permit and monitoring structures that can be used to prevent future discharges of PFAS to the river.
New studies also show that PFAS is likely entering the Spokane River through unregulated sources like historical contamination from the Fairchild Air Force Base. These sources are much more difficult to hold accountable, because they move through a different regulatory process within CERLA, and the state equivalent Model Toxics Control Act. More information about these sources will be coming out in the coming months, and help us better understand how these toxics move through our river system.
After entering the river system, PFAS accumulate in the soil and wildlife. Many wildlife species, particularly fish, are an essential part of the diet of people in many different cultures, increasing the risk to harm to human health from this contamination.
What the Data Shows Us
In 2022, Spokane Riverkeeper joined a nationwide PFAS sampling effort led by Waterkeeper Alliance. We sampled the river in June, during a period of the higher river flows, and used a detection limit of 1 part per trillion (ppt). The goal of the nationwide study was to understand how widespread PFAS is in U.S. waterways and identify possible sources.
Waterkeepers sampled 114 waterways across 34 states and D.C., testing for 55 PFAS compounds. They found that 83% of the sites had detectable levels of PFAS. PFOA and PFOS were the most common, found at 70% of sites—often at levels above the EPA’s interim health advisories. Most of the few non-detect sites were in rural areas, and many had detection limitations.
The results highlight how the east side of the country is ahead of us in understanding their contamination and cleaning up PFAS. As seen in the map below, the east has significantly higher levels of PFAS, making it easier to detect. Without new technology and sampling techniques to test at lower concentrations, we were unable to identify surface water contamination as early as they could. These technological advances are often driven by regulatory pressure, as well as a greater health need.
In Spokane, we sampled the river both upstream and downstream of the wastewater treatment plant. Upstream, no PFAS was detected. Downstream, we found PFOA and PFHxA at 1.6–1.7 ppt. That strongly suggests the treatment plant is a PFAS source. These findings gave us an important snapshot of PFAS in our river, but we still need more data to complete the picture.
What’s Next
In 2024, we launched a PFAS Phase II study, deploying passive samplers near known and suspected sources, including the wastewater treatment plant and sites of biosolids land application. Results will be available this summer, and will help us advocate for stronger regulatory protections from those sources.
To truly protect our river, we need stronger water quality criteria and discharge limits. Without stricter regulations, polluters have little incentive to reduce discharges. Without stricter limits, industries and municipalities have little incentive to reduce their PFAS discharge, leading to continued contamination of our rivers. These enhanced criteria will reduce the likelihood of PFAS buildup in ecosystems, safeguarding both wildlife and water quality. By tightening controls over these sources, we can reduce the amount of PFAS entering the river. This will have an immediate impact on the health of the waterway, preventing further pollution at the source before it can spread.
We also need a targeted study to begin tracing and identifying specific PFAS sources: not just treatment plants, but also industrial discharges, landfills, stormwater, and product use in our communities. It is worth pursuing more targeted testing above and below specific threats in our watershed to better understand how prevalent PFAS may be, and shift us from treating symptoms to stopping pollution at its source.
We also need enhanced monitoring and enforcement. Monitoring is accountability. Increased monitoring would provide data on current PFAS levels, give insight as to how PFAS move through the watershed, and help identify sources of contamination. If we know where PFAS is being released and in what quantities, and have a better understanding of where PFAS are in our system, we can enforce existing laws more effectively.
Finally, more testing is needed to understand how PFAS builds up in fish in the Spokane River. Eating a single serving of contaminated freshwater fish can be the equivalent of drinking water contaminated with high level of PFAS for a month (Barbo, et al, 2023). This is a health risk not just for wildlife but also for people who fish and eat from the river. The most recent studies looked primarily at largescale sucker fish, which had fish tissue concentrations above well above the recommended consumption levels for PFOS (Christie, 2022). However, the sampled fish are not the kinds of fish that are most commonly caught for consumption. Largescale sucker fish are bottom feeders, and would likely have higher concentrations than trout or bass. We need to know what’s in the game fish to keep communities safe.
Studying PFAS levels in wildlife also helps with conservation efforts—especially for animals already affected by things like habitat loss and climate change. Being exposed to PFAS, which are found almost everywhere, could be another reason why some species are declining or going extinct (Ishibashi et al., 2008; Kannan et al., 2006). Little research has been done on the PFAS levels in wildlife along the Spokane River, including game fish relied upon by many community members.
The bottom line is: PFAS pollution isn’t invisible anymore. We now have both the scientific tools and the legal framework to take action. Regulation works—when we use it. The Clean Water Act gives us powerful tools to protect our river, but we need to update and enforce these rules to match today’s challenges.
References
Barbo N, Stoiber T, Naidenko OV, Andrews DQ. Locally caught freshwater fish across the United States are likely a significant source of exposure to PFOS and other perfluorinated compounds. Environmental Research. 2022;220:115165. doi:10.1016/j.envres.2022.115165
Christie E, Shah U, Washington State Department of Health. Fish Advisory Evaluation: PFOS in Fish from Lakes Meridian, Sammamish, and Washington. Washington State Department of Health; 2022. https://doh.wa.gov/sites/default/files/2022-12/334-470.pdf
Ishibashi, H., Iwata, H., Kim, E.-Y., Tao, L., Kannan, K., Amano, M., Miyazaki, N., Tanabe, S., Batoev, V. B., & Petrov, E. A. (2008). Contamination and effects of perfluorochemicals in Baikal seal (Pusa sibirica). 1. Residue level, tissue distribution, and temporal trend. Environmental Science and Technology, 42, 2295–2301. https://doi.org/10.1021/es072054f
Kannan, K., Perrotta, E., & Thomas, N. J. (2006). Association between perfluorinated compounds and pathological conditions in southern sea otters. Environmental Science and Technology, 40, 4943–4948. https://doi.org/10.1021/es060932o