Introduction: New EPA Regulations
Per- and Polyfluoroalkyl Substances (PFAS) are a class of durable, synthetic chemicals linked to adverse health outcomes. Their persistence in the environment and human bodies makes them a top regulatory concern. Because of these concerns, EPA has introduced regulations under the National Primary Drinking Water Regulation, effective April 2024, setting maximum contaminant levels (MCLs) for six PFAS compounds, including PFOA (Perfluorooctanoic Acid) and PFOS (Perfluorooctane Sulfonic Acid) at 4.0 parts per trillion each. Here are some tips for how water operators can prepare for compliance sampling and learn about sampling procedures at treatment plant entry points and in the distribution system.
Tip #1: Follow the initial monitoring requirements
The EPA mandates initial PFAS monitoring by 2027, for community water systems (CWS) and non-transient non-community (NTNC) water systems . The initial monitoring requirements are:
- Four quarterly samples for surface water systems and groundwater systems serving over 10,000 people.
- Two semi-annual samples for groundwater systems serving fewer than 10,000. Ongoing sampling will be determined by first sampling period and initial results.
Tip #2: Follow proper sample protocols
Accurate sampling is critical to avoid contamination. Key dos and don’ts include:
Do:
- Ensure that you find and use only accredited laboratories–set up an account and make sure they are accepting samples.
- Use nitrile gloves and change frequently between sampling to ensure no contamination.
- PFAs water will have to be purchased and provided by lab prior to sampling.
- Ice samples within 15 of collection.
- Ask lab to provide any rules that pertain to sampling, preservation, shipping and transport of samples.
Don’t:
- Use Teflon materials or chemical ice packs.
- Use personal care products like sunscreen, moisturizers, and hair care products before and during sampling.
- Wear waterproof clothing/boots and treated paper products.
Tip #3: Sample at the Entry Point Using EPA-Approved Methods
Samples must be collected at the entry point to the distribution system (EPTDS) after all treatment processes under normal operating conditions. For systems with multiple entry points, a field sample and a field blank are required for each.
Use EPA- approved methods like Method 537.1 for drinking water PFAS analysis. Make sure labs are certified for these methods to meet compliance standards. The EPA provides a fact sheet with information on sample kits, storage and field blank analysis for detailed guidance.
Tip #4: Plan for treatment upgrades and funding
If PFAS levels exceed MCL’s, systems must act by 2029. New treatment options include Granular Activated Carbon (GAC), Reverse Osmosis (RO) and Ion Exchange are new current options to explore for PFAs removal. The Bipartisan Infrastructure Law offers $9 billion for PFAS upgrades, with additional funds through the drinking water state revolving fund and disadvantaged community grants. Exploring funding options sooner rather than later will help systems with future planning and upgrades.
Tip #5: Communicate with your customers
Transparency is important, keeping the public informed of lab results and future needs to the treatment system build trust. Any future PFAs results can be reported on the water systems annual Consumer Confidence Report (CCR) which is mailed and distributed to customers every year.
Tip #6: Train staff early
Preparing now to train staff on sampling procedures and timelines will help ensure compliance with new regulations. Seek out webinars and in-person training to learn more about other systems experiences and to help prepare for future sampling.
Tip #7: Check if your system participated in the UCMR 5
Find out if your water system or any nearby systems were selected by EPA in these last 2 years to participate in Unregulated Contaminant Monitoring Rule 5 (UCMR 5). The systems that did participate in this sampling have test results that are publicly available and include PFAs and Lithium. If PFAS is known and found in your area this will help your system with preparing to develop a representative sampling plan of your water system, secure funding and budget enough money for future sampling, and find an accredited lab. Acting now will help operators and the system meet deadlines and protect public health.
Resources:
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