Monitoring Know-How For PFAS Regulations

By Kevin Westerling,
@KevinOnWater

A Q&A to explain and resolve issues confronting water suppliers as they endeavor to comply with the monitoring requirements of federal PFAS regulations.
The road to an environment — and drinking water — completely free of per- and polyfluoroalkyl substances (PFAS) will be a long one, but the U.S. EPA is working faster than usual to solve the problem of these “forever chemicals.” Before public water systems (PWSs) are mandated to treat down to Maximum Contaminant Levels (MCLs) established by the EPA’s recently finalized rule, PWSs must first monitor for PFAS to see where they stand.
To better understand the new rule and its requirements, as well as best practices for accurate and efficient monitoring, I spoke with Peter Rundell, business development manager and environmental testing expert at Microbac Laboratories. Peter has garnered extensive experience in the industry after having earned a Bachelor of Science in environmental studies from the State University of New York College of Environmental Science and Forestry. He’s at the forefront of understanding and navigating the complexities of environmental testing, particularly in areas like PFAS regulations and compliance, making him ideally suited for this moment, these challenges, and the following Q&A.
On April 10, 2024, the EPA finalized legally enforceable regulations for the National Primary Drinking Water Regulations (NPDWR) under the Safe Drinking Water Act (SDWA) for six PFAS, including PFOA, PFOS, PFHxS, PFNA, HFPO-DA, and mixtures containing two or more of PFHxS, PFNA, HFPO-DA, and PFBS.
Public water systems have three years, until 2027, to complete the initial monitoring phase, followed by ongoing compliance monitoring, outlined below. By 2027, PWSs must also provide public information about PFAS levels in drinking water.
If initial monitoring shows that drinking water levels exceed the maximum contamination levels, then PWSs have five years, until 2029, to implement solutions to reduce PFAS levels. Beginning in 2029, water systems exceeding MCLs are required to take action to reduce the PFAS levels and notify the public of their violation of the MCLs.
What monitoring methods are available for meeting the new rule’s requirements, and how are they fundamentally different?
Within the first three years, Community Water Systems (CWS) and Non-Transient Non-Community Water Systems (NTNCWS) must complete the initial monitoring at all entry points to their distribution system.
Based on system size and source water at an entry point, systems must conduct initial monitoring either twice or quarterly during a 12-month period as follows:
- Surface water systems serving all population sizes: Samples are collected quarterly, two to four months apart, within a 12-month period.
- Groundwater systems serving > 10,000 customers: Samples are collected quarterly, two to four months apart, within a 12-month period.
- Groundwater systems serving ≤ 10,000 customers: Samples are collected twice, five to seven months apart, within a 12-month period.
Alternatively, primacy agencies can allow systems to use previously collected monitoring data to satisfy some or all of the initial monitoring requirements if the sampling data meets the monitoring requirements. Data collected using EPA Methods 533 or 537.1 as part of UCMR 5, state-level, or other appropriate monitoring campaigns will meet the monitoring requirements.
For instance, Microbac Laboratories already conducts analyses following EPA Methods 537.1, which tests for 18 PFAS chemicals. When combined with EPA 533, this tests for 25 total PFAS chemicals. The EPA 533 is considered the gold standard for drinking water analysis as it tests for the most PFAS chemicals. Microbac also conducts analyses following the new official EPA 1633 method, which tests for 40 PFAS chemicals in groundwater, wastewater, sludges, and solids.
After the initial monitoring phase, PWSs must begin ongoing compliance monitoring at all entry points to the distribution system. What is required for ongoing compliance monitoring will be based on the results of the initial monitoring data. If samples have PFAS levels above the trigger at an entry point, they must perform quarterly sampling. After four consecutive samples at less than the trigger, they can reduce sampling to once yearly. Then, after three years of levels less than the trigger, it can be reduced to triennial (once every three years) compliance monitoring. On the other hand, if system samples are already less than the trigger values at the entry point during the initial monitoring phase, the sampling frequency can be reduced to triennial at the end of that initial three years. Systems with multiple entry points may establish different compliance monitoring schedules for each entry point depending on their monitoring results.
What considerations come into play for choosing the best monitoring tool for a particular water system?
The EPA encourages all PWSs to contact their state laboratory certification program to seek state primacy program guidance on selecting a qualified lab to complete PFAS testing requirements. Even if your state does not yet have a certification program for PFAS, the EPA still prefers that you contact them to help guide you in selecting a qualified laboratory. They will likely direct you to a laboratory that is certified nationally to monitor PFAS under the UCMR 5 Program rather than choosing a laboratory that is not certified.
What are some monitoring pitfalls or common mistakes for operators to avoid?
The most common monitoring mistake is not following the sampling guidelines established by the states or laboratories; be sure to follow your laboratory’s recommendations closely.
Another common issue is that, since PFAS limits are set very low, it can be easy to accidentally introduce PFAS into the samples from outside the water source. There are multiple precautions you can take on testing day to avoid this. For instance, avoid wearing clothing or boots with waterproofing like Gore-Tex, Tyvek, etc. Additionally, certain fabric softeners, fragrances, cosmetics, moisturizers, sunscreens, and insect repellents may also contain PFAS, so avoid wearing those on the day of sampling. Latex gloves must also be avoided as they contain PFAS; powderless nitrile gloves are a safer alternative but may still contain low levels of certain PFAS, so be sure the gloves only touch the outside of the sampling bottle. Finally, do not use permanent markers, Post-it notes, or waterproof paper since many also contain PFAS; use only ballpoint pens and regular notepads without sticky adhesives or waterproofing.
Conversely, are there tips or tricks to improve monitoring outcomes?
Here are some tips to improve outcomes and ensure more accurate test results.
- Always have a plan in place before you proceed.
- Always follow the list of sampling precautions that your laboratory provides.
- To avoid contamination of the samples, follow all the recommendations above to avoid using anything on sampling day that could contain PFAS (e.g., avoid GoreTex, sunscreen, insect repellants, latex gloves, permanent markers, etc.).
- Collect only your PFAS samples on the day of collection, or at least collect them first. Do not collect other samples with them because some sampling bottles contain Teflon.
- Make sure the samples are iced and placed in a clean cooler. If using blue ice blocks, ensure they are certified PFAS-free.
- Use the same cooler each time you do your PFAS sampling and only use it for PFAS samples; never store other samples in it.
What role does monitoring play on the wastewater/ industrial side, for PFAS source identification, control, and treatment?
Monitoring the wastewater/industrial side can play an important role in seeing what is coming from the upstream side. Some states have instituted requirements for monitoring for PFAS or absorbable organic fluorine (AOF) in the influent, effluent, and industrial sludges for wastewater treatment plants. Some states have eliminated the use of PFAS in products made in their states. These measures will help eliminate PFAS at the entry point of PWSs and the environment.
The new method for wastewater and sludge monitoring is EPA 1633, which covers 40 PFAS chemicals. Some laboratories are using other methods, such as AOF and TOF (total organic fluorine), but these do not measure individual PFAS chemicals and are used more as a screening method to help indicate the need for further testing. The testing of PFAS has evolved greatly over the last 10 years and will likely continue to evolve as new chemicals are added to the monitoring requirements.
There are many ways of controlling and treating PFAS in water systems. Resins, granular activated carbon, and reverse osmosis are currently being used to remove PFAS from drinking water. Many new technologies are also currently being developed.
What are the biggest challenges about PFAS rules compliance, and how can they be overcome?
Since the PFAS limits are set very low, it may be difficult for many systems to comply with the SDWA regulations when their levels are at or above the regulation limit. They will have to comply by implementing expensive systems to remove the PFAS from their drinking water. It will take time before PFAS sources are reduced, which puts the financial burden of addressing PFAS on the PWSs. This may be difficult for some systems, which may have to rely on taxpayer money to pay for it. Additionally, many individuals, municipalities, and states are now suing the companies that produce PFAS to help compensate them for cleanup costs.
The PFAS program is expected to evolve in the future to include additional PFAS chemicals that are not yet regulated. New test methods are currently identifying 30 or more chemicals that are not considered in the newly adopted regulations.
About The Author
Kevin Westerling is chief editor of Water Online and has been covering the industry for more than 15 years. He can be reached at kwesterling@wateronline.com.