PFAS Landfill Sampling Memo 2023-03-13

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
March 13, 2023
MEMORANDUM
To: Solid Waste Directors and Lan wners/Operators
From: Ed Mussler, Section Chief
NC Division of Waste Management, Sold Waste Section
Re: PFAS Monitoring Requirements for Solid Waste Sanitary Landfills
Background
Per -and polyfluoroalkyl substances (PFAS) are a group of manufactured compounds used in a
variety of industries, such as aerospace, automotive, textiles, and electronics, and are widely used
in commercial and consumer products such as food packaging, water- and stain -repellent fabrics,
nonstick products, and firefighting foams. Many of these products and by-products are commonly
disposed in solid waste landfills. PFAS, including perfluorooctane sulfonic acid (PFOS) and
perfluorooctanoic acid (PFOA), are a concern because they:
• do not break down in the environment,
• can move through soils and contaminate drinking water sources,
• build up (bioaccumulate) in fish and wildlife, and
• have been linked to adverse health effects in humans and animals.
PFAS Sampling
The Solid Waste Section (Section) is requiring that all groundwater, surface water, and leachate
samples collected at solid waste sanitary landfills after July 1, 2023 be analyzed for per- and
polyfluorinated substances (PFAS), in accordance with the requirements and procedures for
groundwater and surface water monitoring established under 15A NCAC 13B Rules .0601, .0602,
.0544, .0545, .1623, and .1630 through .1637, 15A NCAC 02L, and the provisions of G.S. 143-
215.1(a). This includes any active, inactive, or closed sanitary landfill currently conducting and
reporting water quality and/or leachate sampling results to the Section.
The Section has determined that all sanitary landfills analyze groundwater, surface water, and
leachate samples for PFAS to ensure protection of human health and the environment due to the
potential health hazards associated with PFAS. This requirement is in conjunction with the NC
DEQ's Action Strategy for PFAS to manage the risks of PFAS in the State. Landfills are one of
several priority areas in the plan and sampling will help to identify possible PFAS associated with
the regulated management of solid waste and to evaluate the presence of PFAS in the environment
from these managed activities. Collection and evaluation of this information will also assist the
Department in developing sound policies with respect to PFAS in the environment.
E Q North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
NORTH CAROLINA -
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Sampling Frequency and Laboratory Analytical Methods for PFAS
Collection of samples for PFAS analysis should be conducted for all monitoring locations
(groundwater, surface water, underdrain, and leachate) and during the landfill facility's regular
compliance monitoring schedule as required by the facility permit and/or most current approved
water quality monitoring plan.
The Section is requiring groundwater, surface water, and leachate samples to be analyzed using
EPA (Draft) Method 1633 for the full list of PFAS compounds for the method. Please note that
specific considerations and protocols are required to avoid cross -contamination and minimize
sample bias for PFAS.
A current listing of laboratories accredited to perform EPA Draft Method 1633 can be found here:
https://www.denix.osd.mil/edqw/accreditation/accreditedlabs/index.html. To view the labs,
search for `Draft EPA Method 1633' under Methods. Please note that different labs are accredited
for different matrices.
NOTES - Sampling and Analytical:
• The analytical methods should be the most recent versions of the analytical method(s) stated
above. Sampling must be planned so that required holding times for analytical methods are met.
• EPA Draft Method 1633 is currently single -lab validated and is expected to soon become multi -
lab validated. The method will undergo QC with a current expected time to be Final in 2023 or
2024.
• The Section considers ` J"flag values valid and relevant in the decision -making process and hence
all `J"flag values should be reported.
• Online technical resources on PFAS sampling protocols, fact sheets, analytical methods, and other
issues, can be found here: Interstate Technology and Regulatory Council (ITRC) PFAS Website
Reporting
PFAS analytical results must be reported as part of the regularly submitted monitoring report
along with the laboratory data report (electronic format pdf copy). Laboratory data must be
submitted in accordance with the most current DEQ electronic data deliverable format (EQUIS).
If you have any questions, please contact Perry Sugg, Environmental Compliance Branch Head,
at [phone] or via email at perry.sugg&ncdenr.gov.
Thank you for your cooperation in this matter.
E Q North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
NORTH CAROLINA -
DaP.mm.mmEwimnm�lQu.� /� 919.707.8200