PFAS MONITORING AND

REQUIREMENTS OF ACT 21/S.49

DRINKING WATER AND GROUNDWATER PROTECTION DIVISION

2019

WHAT ARE PFAS?

PFAS stands for a group of chemicals called PER AND POLYFLUOROALKYL SUBSTANCES.

➢ group of (4000+) man-made chemicals that have been used in industry and consumer products since

the 1950s because they are resistant to heat, water, and oil

Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonic acid (PFOS) are most prevalent and

most studied

PFAS are very stable

PFAS do not break down readily in the body or the environment

➢ found in people’s blood, wildlife, fish all over the world (even polar bears)

➢ can take many years to leave the body even after exposure stops

2

WHAT ARE PFAS? CONT’D

PFOA and PFOS have been phased out by industry and no longer manufactured or

imported in the United States - but still persistent in the environment

similar replacement PFAS chemicals like GenX remain.

➢ GenX is the trade name for technology used to make non-stick coatings without

the use of PFOA. GenX can refer to multiple compounds

PFAS are chemicals formed from carbon chains with fluorine-carbon

bonds which are extremely strong and difficult to break down in the environment

and our bodies

3

LONG CHAIN VS SHORT CHAIN PFAS

Long Chain

➢ greater number of carbon molecules and

are more toxic and bioaccumulate

Short Chain

➢ with fewer carbons and considered less

toxic

4

This Photo by

Unknown Author is

licensed under CC

BY

REGULATED PFAS CONTAMINANTS (5)

• PFOA (perfluorooctanoic acid)

• PFOS (perfluorooctane sulfonic acid)

• PFHxS (perfluorohexane sulfonic acid)

• PFHpA (perfluoroheptanoic acid)

• PFNA (perfluorononanoic acid)

5

WHAT ARE PFAS? CONT’D 6

PFHpA is a breakdown product of stain and grease-proof coatings

* Underlined PFAS are currently regulated

SOURCES OF PFAS

Industrial sites in manufacturing and use of non-stick coatings such as Teflon®, waterproof fabric

manufacturing, semi-conductor and battery manufacturers, tanneries

Fire training/fire response sites due to the use of Aqueous Film-Forming Foam (AFFF)

Landfills

Wastewater treatment plant releases/biosolids

• wire coating facilities

This Photo by Unknown Author is licensed under CC BY-SA

This Photo by Unknown Author is licensed under CC BY-SA

7

SOURCES OF PFAS 8

PRODUCTS CONTAINING PFAS

Water resistant clothing such as Gore-Tex™

Non-stick coatings such as Teflon® (polytetrafluoroethylene or PTFE)

Stain resistant treatments such as Scotchgard ®

Water resistant building materials such as Tyvek® Material

Waterproof/treated paper or field books, plastic clipboards

Post-It® and other adhesive paper products.

Pre-packaged food, fast food wrappers, pizza boxes,

and food containers

Cosmetics, shampoo

9

This Photo by Unknown Author is licensed

under CC BY-SA

PFAS ENVIRONMENTAL FATE AND TRANSPORT 10

SO HOW DID WE GET HERE?

Hoosick Falls, NY – PFOA from Saint-Gobain Performance Plastics

North Bennington, Bennington – Former CHEMFAB Teflon fabric-coating facilities

11

PFAS REGULATION TIMELINE

➢2009 EPA issues provisional health advisory for PFOA at 400 ppt and PFOS at 200 ppt

➢2016 EPA establishes 70 ppt health advisory for the sum of PFOA and PFOS

➢2016 Vermont establishes 20 ppt health advisory for sum of PFOA and PFOS

➢2018 Vermont updates 20 ppt health advisory to include additional PFAS

similar to PFOA and PFOS (total of 5 PFAS)

➢2019 Act 21 establishes an interim maximum contaminant level (MCL)

for 5 same PFAS at 20 ppt

ppt = parts per trillion

13

EPA HEALTH ADVISORY VS. VERMONT MCL

No federal MCL exists for PFAS, but EPA has a lifetime health advisory of

70 parts per trillion (ppt) for PFOA and PFOS only

• Based on exposure to a lactating woman and adverse developmental health effects to

the most sensitive populations (i.e. fetuses during pregnancy and breastfed infants)

In Vermont, the standard (currently an interim MCL) is 20 parts per trillion (ppt) for the sum of

any combination of PFOA, PFOS, PFHxS, PFHpA and PFNA

• Based on exposure to an infant. Because an infant drinks more water per body weight

than an adult woman, the dose to the infant is higher than the dose to the adult

woman

14

HEALTH EFFECTS OF PFAS

Scientific studies in people suggest certain PFAS may:

• Affect growth, learning and behavior of babies and older children

• Lower a woman’s chance of getting pregnant

• Interfere with the body’s natural hormones

• Increase cholesterol levels

• Affect the immune system

• Increase the risk of cancer

Health effects may be the same for pets. If you are concerned, you can give your pet bottled

water or water from a known source that does not contain PFAS

15

BACKGROUND

Data acquired under EPA’s Third Unregulated Contaminant Monitoring Rule

(UCMR 3) for 6 PFAS listed here

10 community water systems were sampled between 2013 - 2015

and were non-detect

• Reporting limits were considerably higher at that time

Targeted sampling around the State based on location, industrial,

and land uses

• State Fire Academy – Pittsford

• Airports from use of AFFF – Clarendon, Rutland

• Pownal, Bennington, North Bennington, Shaftsbury

• multiple public systems and private wells were sampled due to

proximity to a source of potential contamination

ContaminantUCMR 3 Reporting Limit

(ppt)

PFBS 90

PFHpA 10

PFHxS 30

PFNA 20

PFOA 20

PFOS 40

Pilot study at 10 schools throughout the state in 2018 due to proximity to source of contamination

16

BACKGROUND

Detections found:

of 10 schools tested

• 2 with PFAS above 20 ppt – GAC (Granular Activated Carbon) treatment installed

6 of the public water systems in areas of concern tested had PFAS above 20 ppt

• 4 TNCs in Bennington area

• 1 Community system - Pownal Fire District 2 – source is wire-coating facility

• 1 NTNC - Rutland Regional Airport Business Park – likely from AFFF due to airplane crash

✓ Treatment has been installed at each system and finished water is non-detect for PFAS

17

REGULATED PFAS CONTAMINANTS (5)

• PFOA (perfluorooctanoic acid)

• PFOS (perfluorooctane sulfonic acid)

• PFHxS (perfluorohexane sulfonic acid)

• PFHpA (perfluoroheptanoic acid)

• PFNA (perfluorononanoic acid)

18

PFAS MCL

The interim Maximum Contaminant Level (MCL) for PFAS is 20 parts per

trillion (ppt) or 20 nanograms per liter (ng/L) for the sum of 5 PFAS (PFOA,

PFOS, PFHxS, PFHpA, and PFNA)

(individually or in any combination)

• 1 ppt equals 1 ng/L (labs will likely report data in ng/L)

Which means for these 5 PFAS, if each analyte is detected at 4.5 ng/L it

would equal an MCL exceedance…

19

PFAS MCL CALCS

Examples:

Results (in ng/L) The MCL is 20, not 20.0

Detection of 2.0 ng/L is equal to 0.000002 mg/L - looking at low low numbers!

Fun fact: Of the 94 million mile distance from EARTH to the SUN, 1 ppt is the

equivalent of moving 6 inches of the total distance

PFOA PFOS PFNA PFHxS PFHxA Total regulated PFAS

concentration in

sample

4.5 4.5 4.5 4.5 4.5 22.5 rounds to 23

20.4 0 0 0 0 20.4 rounds to 20

10.0 10.5 0 0 0 20.5 rounds to 21

20

ACT 21 (S. 49) MONITORING REQUIREMENTS

All public community water systems (PCWS) and non-transient non-community (NTNC) systems must

sample the active entry point(s) to distribution for PFAS by December 1, 2019

• Follow your routine monitoring schedule which has been updated and available online at:

https://anrweb.vt.gov/DEC/DWGWP/

• Systems that do not perform required sampling will be in violation

• Combined sources:

There may be more than one entry point per water system. If water is drawn from more than one

source and the sources are combined before distribution, a sample shall be collected where

water is representative of all permitted sources supplying that entry point.

• Composite sampling among multiple entry points is not allowed.

• TNCs are not required to sample for PFAS under the Act

21

ACT 21 (S. 49) MONITORING CONT’D

In other words, a blended sample taken during normal operating conditions is appropriate and collect

PFAS sample in the same location as your routine IOCs, SOCs, VOCs, Nitrate, and Radionuclides

• Collect sample from your point of entry to distribution (not entry to treatment system)

• Collect sample from finished water following all treatment and CT, prior to or at the first user in DS

• follow your routine monitoring schedule (use Facility ID and Sample PT codes found on monitoring

schedule – your entry point will be listed there)

• this is NOT a raw water source sample taken from each well

• PFAS monitoring (named PFAS via 537.1) has been added to all Community and NTNC monitoring

schedules at each required entry point(s) to distribution

22

HTTPS://ANRWEB.VT.GOV/DEC/DWGWP/

WHERE IS MY MONITORING SCHEDULE? 23

Or go to http://dec.vermont.gov/water and click on PWS monitoring schedules

WHERE DO I FIND MY FACILITY ID?

A Facility ID = code in our database about your water system

infrastructure

24

Facility Name will

be listed here

WHERE DO I FIND MY SAMPLE POINT?

A Sample Point = code tied to a Facility ID

identifying where to take your sample

25

Sample Site = description

of your sampling point in

our database.

This is often listed as

“location” on your COC

26FILLING OUT LABORATORY PAPERWORK

VT0005317TP002

EP002Cavendish Town

Entry point

(after storage

and CT)

Raw Water

ENTRY POINT TO DISTRIBUTION

An entry point to

distribution sample

(entry point) is to be

collected from finished

water after all

treatment and storage,

at or before the first

user

The water system

should have a

dedicated finished

water sampling tap

Distribution

System

27

ENTRY POINT EXERCISE

Where is the entry point in each of

these water system examples?

28

SUMMARY OF REQUIREMENTS FROM ACT 21 FOR PUBLIC WATER SUPPLIES

1. Interim MCL applies and testing required by 12/1/2019

2. If 20 ng/l exceeded during initial monitoring, system must remedy by exploring new

source(s) or installing treatment and issue Do Not Drink public notice quarterly until

resolved

3. MCL must be established in Water Supply Rule by 2/1/2020

4. Adjustments to the 20 ng/l can be made for MCL (EPA develops MCLs with cost and

technical feasibility criteria)

5. Publish Advanced Notice of Proposed Rulemaking for PFAS as a class by 8/1/2020

6. File a proposed rule to regulate PFAS as a class by 3/1/2021 or not to regulate, given

legal, technical or other impediments.

29

SUMMARY OF REQUIREMENTS FROM ACT 21 FOR PUBLIC WATER SUPPLIES

7. Pilot study at a public water system using a total oxidizable precursor assay or other method

to identify total PFAS, by 7/1/2019

8. Publish a plan for public comment to collect data for contaminants in drinking water from

public community water systems and NTNCs, for which a health advisory has been

established but no MCL has been adopted.

30

ACT 21 MONITORING REQUIREMENTS

• If non-detect (i.e. < 2 ng/L) no follow-up required other than to sample again in 3 years

• If detected between 2 and 19 ng/L (i.e results up to 19.4) must sample annually and

schedule set to equivalent quarter in following year

• If detected at 20 ng/L (i.e. results between 19.5 and 20.4) quarterly monitoring required

• Above 20 ng/L ( i.e. 20.5 or higher) require confirmation (if not already on quarterly) and

take average of results

➢Confirmed above 20 ng/L (by average) will be required to install treatment and/or seek

new source(s)

➢Required to post Do Not Drink (DND) notice to all users with required health language

Sample early (allow labs time to meet method holding times and avoid a monitoring violation

if samples are rejected)!!

The final proposed WSR may ultimately contain different requirements, but we are currently

operating per Act 21

31

This Photo by Unknown

Author is licensed under

CC BY-SA-NC

CONFIRMATION SAMPLES

➢Confirmation samples must be collected as soon as reasonably possible, but not to

exceed two weeks (14 days) from receipt of initial results

➢ If initial sample concentration for any of the 5 regulated PFAS is 40.5 ng/L or higher,

immediate Do Not Drink (DND) notice issued to the system users and quarterly

monitoring required

➢Do Not Drink notice is being issued based on the detections of the 5 regulated PFAS

(PFOA, PFOS, PFHxS, PFHpA, and PFNA) only

32

PFAS SAMPLE KIT

• Multiple (at least two) pre-preserved 250mL high-density polyethylene (HDPE) or polypropylene

sample bottles with polypropylene screw caps (must be unlined caps)

➢ Pre-preserved bottles with Trizma crystals which act as a buffer and dechlorinating agent

• Laboratory reagent field blank (to be prepared by sampler in field) for each entry point sampling

location

➢ Should include an empty unpreserved container for preparation in field

• Laboratory prepared trip blank (NOT to be opened) – 1 per kit

• Sample cooler (may contain PFAS free ice packs that need to be frozen before returning sample to

lab)

➢ Otherwise use regular ice

• Powderless nitrile gloves (1 new pair for each sampling location)

• Multiple resealable polyethylene storage bags (i.e .Ziploc bags) to store sample containers after

sampling and for shipping

• Lab paperwork for sample number tracking and chain of custody

33

PFAS SAMPLE KIT 34

PFAS SAMPLE KIT 35

FIELD BLANK PREP

In order to determine whether PFAS may have been introduced during sample collection and

handling, a field reagent blank shall also be collected from each sampling site and at the same

time of sampling. Prepare your field blank first before collecting your sample and collect PFAS

samples before any other sampling parameter that day.

Field blanks shall be prepared as follows:

a) Open the Field Reagent Blank at the location of the sampling site and pour the reagent

water into the empty (unpreserved) sample bottle that came with the Field Reagent

Blank.

b) Seal the field blank sample bottle.

c) Label the sample bottle as the Field Reagent Blank for the associated sampling site and

ship it back to the laboratory along with the sample for that sampling site.

36

TRIP BLANKS

➢1 Trip Blank per kit

Trip blanks shall be prepared by the laboratory in advance and follow the sample containers and

same shipping containers as the samples and returned to laboratory. Trip Blanks shall not be

opened.

*Field Blanks and Trip Blanks will only need to be analyzed/reported if any of the 5 regulated

PFAS are detected in the samples.

(Labs may need to analyze anyway due to short method holding time)

37

CONTRACT SAMPLING INFO

This sampling is NOT being paid for by the state

State contractor is acting as a “consultant” who is experienced in taking PFAS samples

Weston and Sampson (Waterbury)- $1,096

Cost per additional sample if more than one entry point to distribution $475

Contact: Steven LaRosa 802-244-5051 x6007 or larosas@wseinc.com

Aquaterra (North Ferrisburgh) - $535

Cost per additional sample if more than one entry point to distribution $265

Contact: Roland Luxenberg 802-238-0071 or roland@luxenberg.us

2 ng/L is equal to 0.000002 mg/L so very low numbers!!

38

HOW TO SAMPLE?

1. The sampler shall wash their hands before sampling and wear new powderless nitrile gloves while filling

and sealing the sample bottles. Collect PFAS samples first before any other sampling parameter!

2. Turn on the tap and flush the cold water (with aerator removed) until the water temperature stabilizes

(approximately 5 minutes). Reduce flow to avoid splashing. Do not sample from a garden hose,

analyzer tubing, or irrigation devices. Use only cold water for sampling.

3. Fill sample bottles such that sample preservation reagent is not flushed out. It is acceptable for the

sample bottle to have headspace.

4. After collecting the samples, cap the bottle and agitate by hand until the preservative is dissolved.

5. Label the bottle with the associated sampling location and indicate Facility ID, Sample Point, and WSID

on the chain of custody (lab paperwork).

6. Keep the sample sealed from the time of collection until delivered to the laboratory (multiple Ziploc

bags are recommended).

7. Chill samples during shipment; samples shall not exceed 10 degrees Celsius (50 degrees Fahrenheit)

until received by the laboratory. Do not allow samples to freeze!

39

Things that might contaminate samples:

pumps and tubing with Teflon® - PTFE and other

fluoropolymer containing materials

glass or low-density polyethylene (LDPE) sample containers

permanent markers

contact with carpeting or upholstery inside buildings and

vehicles

waterproof paper or field books, Post-it notes

Clothing and boots treated with a water repellant or stain

resistant material like Goretex ®, Scotchgard® or Tyvek ®

BE CAREFUL NOT TO CONTAMINATE THE SAMPLE! 40

Things that might contaminate samples:

• Personal Care Products used (on day of sample collection) such as

cosmetics, moisturizers, hand cream and other related products

• pre-packaged food, fast food wrappers, pizza boxes or food containers

• chemical gel or (blue) ice packs

BE CAREFUL NOT TO CONTAMINATE THE SAMPLE!

This Photo by Unknown Author is licensed under CC

BY-SA

This Photo by Unknown Author is licensed under CC BY-SA

41

• No decontamination soap with fluorinated surfactants like Decon 90

• Wait until after sample collection and preparing for shipping

before eating or drinking

BE CAREFUL NOT TO CONTAMINATE THE SAMPLE! 42

Powderless Nitrile gloves

HDPE and polypropylene materials, silicone tubing

Plain Paper, metal clipboard, ball-point pens

Clothes made of synthetic or cotton material untreated with water or

stain repellants and previously laundered (preferably washed greater

than six times) without the use of fabric softeners

WHAT’S OK 43

Sunscreens:

Alba Organics Natural

Yes to Cucumbers

Aubrey Organics

Jason Natural Sun Block

Kiss My Face

Baby-safe sunscreens (‘free’ or ‘natural’)

Insect Repellents:

Jason Natural Quit Bugging Me

Repel Lemon Eucalyptus

Herbal Armor

California Baby Natural bug spray

Babyganics

Sunscreen and Insect Repellents:

Avon Skin So Soft Bug Guard-SPF 30

WHAT’S OK 44

Polyethylene storage bags such as Ziploc® –

Sample containers should be stored inside

sealable bags provided and transported in

coolers

Try to collect samples within 4 days of receiving

your sample kit

Use PFAS free ice packs if provided by lab or

regular ice when preparing for shipping

WHAT’S OK

This Photo by Unknown Author is licensed under CC BY-SA

45

EPA Method 537.1

• The recommendations for determining a detection limit (DL) and reporting limit (RL) in method

537.1 shall be followed. (this is why we require NELAP certification)

• The maximum acceptable laboratory reporting limit for each respective analyte for

PFOA, PFOS, PFHxS, PFHpA, and PFNA is 2 ng/L.

• This allows for quantitation to ½ the 20 ppt MCL which mean more reliable data

• This is important because of significant remediation costs imposed on water systems if they exceed

the MCL

• Sampling results shall be reported to the nearest 0.1 ng/L.

• All analytical laboratory reports shall report on all 18 analytes identified in EPA Method 537.1.

LABORATORY AND REPORTING GUIDANCE 46

ALL (18) ANALYTES REQUIRED BY EPA METHOD 537.1

This Photo by Unknown Author is licensed under CC BY-SA

47

EPA METHOD 537 (2009) VERSUS 537.1 (2018 UPDATE)

• Method 537 version 1.1 (2009) was used for monitoring under UCMR

• Method 537.1 (2018) replaces 537

o 537.1 achieves lower reporting and detection limits

• 537.1 adds 4 additional analytes that have similar properties to previously identified PFAS and are still in

use today

o Hexafluoropropylene oxide dimer acid (GenX chemical)

o 11-chloroeicosafluoro-3-ozaundecane-1-sulfonic acid (11Cl-PF3OUdS)

o 9-chlorohexadecafluoro-3-oxanone-1-sulfonic acid (9Cl-PF3ONS)

o 4,8-dioxa-3H-perfluorononanoic acid (ADONA)

• Act 21 requires most recent method version 537.1 to be used due to the ability to detect “the maximum

number of PFAS detectable from standard laboratory methods”

• Only methods 537 and 537.1 have been recognized by EPA for analysis of PFAS although other less-

studied methods are out there

48

HOW TO SUBMIT DATA?

• Have laboratory submit data electronically by Excel or CSV file (we have a specific template

for them to use for submittal)

• scan PDF of lab report and submit by email to ANR.DWpfasdata@vermont.gov

• If you use the state contractor for sampling they are required to follow PFAS data submittal

procedures under the contract.

49

HOW DO I FIND A NELAP CERTIFIED LAB?

Go to our PFAS website for the current list of certified labs that perform

EPA Method 537.1:

https://dec.vermont.gov/water/drinking-water/water-quality-monitoring/pfas

50

AFTER INITIAL MONITORING 51

AFTER INITIAL MONITORING

If the sum of PFOA, PFOS, PFHxS, PFHpA or PFNA are

detected greater than 20 ppt (20.5 or higher)

➢Immediately collect a confirmation sample (within two weeks)

➢Calculate the average of the initial and confirmation samples:

o If the average is 20 ppt or higher, begin quarterly PFAS monitoring

o If the average is GREATER than 20 ppt a DO NOT DRINK notice must

be issued within 24 hours

o If the average is GREATER than 20 ppt corrective action is required

52

AFTER INITIAL MONITORING

If the sum of PFOA, PFOS, PFHxS, PFHpA

or PFNA are detected at 20 ppt

(between 19.5 and 20.4)

➢monitor for PFAS on a quarterly basis

53

AFTER INITIAL MONITORING

If the sum of PFOA, PFOS, PFHxS, PFHpA

or PFNA are detected less than 20 ppt

(between 2 and 19.4)

➢Continue to monitor for PFAS annually

54

AFTER INITIAL MONITORING

If PFOA, PFOS, PFHxS, PFHpA or PFNA are

not detected (less than 2 ppt)

➢Continue to monitor for PFAS every three years

PUBLIC NOTICE

A DO NOT DRINK notice will be

required if the average of the

initial and confirmation samples

exceed 20 ppt OR if initial

sample is 41 ppt or higher.

56

Go to our website for the Do Not Drink public

Notice template:

https://dec.vermont.gov/water/drinking-

water/water-quality-monitoring/pfas

DO NOT DRINK NOTICE

What should I do?

• DO NOT DRINK THE WATER. Do NOT use the water for drinking or cooking, brushing teeth,

making ice cubes, making baby formula, washing fruits and vegetables, or any other

consumptive use.

• Use another source of water for consumption which may include bottled water.

• Water may be used for other uses when you don’t swallow the water, such as showering,

bathing, or washing clothes or dishes. Try to limit the amount of water children swallow

while bathing.

• Do NOT use water containing the five PFAS over 20 ppt to water your garden. The PFAS

could be taken up by the vegetables.

• DO NOT BOIL THE WATER. Boiling the water will not remove PFAS and may concentrate

them.

• If you have specific health concerns, contact your health care professional.

57

DO NOT DRINK NOTICE

What does this mean?

PFAS is a group of chemicals that may affect different systems in the body. Although more

research is needed, some studies in people have shown that these chemicals may affect

growth, learning, and behavior in babies and children; lower a woman’s chance of getting

pregnant; interfere with the body’s natural hormones; increase cholesterol levels; affect the

immune system; and increase the risk of cancer. These health effects may be the same for

pets. If you are concerned, you can give your pet bottled water or water from a known safe

source.

58

NOTICE TO USERS OF A PFAS DETECTION

Water systems are not

required to provide notice

for sample results at or

below 20 ppt.

59

PFAS REFERENCES/RESOURCES

https://dec.vermont.gov/water/drinking-water/water-quality-monitoring/pfas

https://dec.vermont.gov/pfas

PFAS Monitoring Results Received (https://anrweb.vt.gov/DEC/DWGWP/license.aspx?Report=PFASData)

https://www.epa.gov/pfas

https://www.epa.gov/ground-water-and-drinking-water/supporting-documents-drinking-water-health-advisories-pfoa-

and-pfos

https://www.asdwa.org/wp-content/uploads/2019/02/ASDWA-PFAS-Lab-Testing-Primer-02-14-19-Final-V2.pdf

https://pfas-1.itrcweb.org/fact-sheets/

https://www.nj.gov/dep/watersupply/pdf/pfna-pfas-sampling-guidance-for-nj-water-systems.pdf

https://www.stripes.com/news/us/maine-task-force-on-pfas-forever-chemicals-begins-work-this-week-1.581884/pfas-

graphic-1.581886#gallery

https://www.awwa.org/Portals/0/AWWA/Government/AWWAPFCFactSheetPrevalenceandAssessment.pdf?ver=2018-

12-13-101923-060

60