Monitored Natural Attenuation to Manage PFAS Impacts to Groundwater: Scientific Basis

Sites impacted by per- and polyfluoroalkyl substances (PFAS) pose significant challenges to investigation and remediation, including very low cleanup objectives, limited information on natural PFAS degradation processes in the subsurface, and the apparent mobility and persistence of PFAS. Consequently, monitored natural attenuation (MNA) may be considered less applicable to PFAS compared to biodegradable classes of chemicals such as petroleum hydrocarbons and chlorinated solvents that can completely biodegrade to innocuous end products. However, MNA has proven effective for certain non-degrading metals, metalloids, and radionuclides (e.g., chromium, arsenic, and uranium). To assess the applicability of MNA to PFAS, this paper reviews the fate and transport properties of PFAS in conjunction with the various physiochemical factors that control the subsurface movement of chemicals. This analysis demonstrates that two important retention processes: (1) chemical retention in the form of PFAS precursors, and (2) geochemical retention in the form of sorption and matrix diffusion to mitigate the movement and potential impacts of PFAS in groundwater that may form the scientific basis for applying MNA to PFAS contamination. This paper describes the scientific and regulatory basis for using MNA to manage PFAS-impacted groundwater.