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HomeMy WebLinkAboutDEQ-CFW_00069699F 1 SITE CHARACTERIZATION TOOLS, SAMPLING TECHNIQUES, AND 2 LABORATORY ANALYTICAL METHODS SUMMARY FACT SHEET 3 4 REVIEW DRAFT 5 6 DO NOT CITE OR QUOTE 7 8 July 12, 2017 9 1 INTRODUCTION 10 This fact sheet is one of six developed by the Interstate Technology and Regulatory Council 11 (ITRC) to provide an overview of the site characterization tools, sampling techniques, and 12 analytical methods available for use when evaluating PFAS concentrations in environmental 13 samples. The fact sheets are tailored to the needs of state regulatory program personnel who are 14 tasked with making informed and timely decisions regarding PFAS-impacted sites. The content 15 is also useful to consultants and parties responsible for the release of these contaminants, as well 16 as public and tribal stakeholders. The information in this fact sheet is supplemented by others in 17 the series: Nomenclature Overview and Physical and Chemical Properties; History and Use; 18 Regulatory Summary; Environmental Fate and Transport (to be published late 2017); and 19 Remediation Technologies and Methods (to be published late 2017). 20 This Fact Sheet provides information and considerations for sites and sources of PFAS to the 21 environment that is special or unique to PFAS, including: 22 • Information about site characterization 23 • Sampling methods 24 • Analytical methods. 25 1.1 What are PFAS? 26 PFAS are a complex family of more than 3,000 manmade fluorinated organic chemicals (Wang 27 et al. 2017). These substances have a carbon chain structure containing at least one totally 28 fluorinated carbon atom. PFAS include both per- and poly -fluorinated chemicals. Perfluorinated 29 chemicals, such as perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS), are a 30 subset of PFAS with carbon chain atoms that are totally fluorinated, while polyfluorinated 31 chemicals have at least one carbon chain atom that is not totally fluorinated (Buck et al. 2011). 32 Due to unique physical and chemical properties (for example, surfactant, oil -repelling, water- 33 repelling), PFAS have been extensively manufactured and used worldwide. Some PFAS 34 molecules are environmentally stable, mobile, persistent, and bioaccumulative. Further 35 discussion is in the Nomenclature Overview and Physical and Chemical Properties, Regulatory 36 Summary and History and Use Fact Sheets. 37 DEQ-CFW 00069699 A 38 1.2 Why Are PFAS Important? 39 The scientific community is rapidly recognizing and evolving its understanding of PFAS in the 40 environment. PFAS in the environment are considered to be contaminants of emerging concern 41 (CECs). CECs are those chemicals that present known or potentially unacceptable human health 42 effects, or environmental risks, and either: (i) do not have regulatory cleanup standards, or (ii) 43 the regulatory standards are evolving due to new science, detection capabilities, or pathways, or 44 both (USDOD 2009). 45 PFAS are found globally in both remote and urban environments, and ar sent in various 46 matrices including: human blood (whole, plasma and serum), sedime ace and 47 groundwater, and wildlife (Kannan et al. 2004, Yamashita et al. 20 s et al. 2005, 48 Rankin et al. 2016). Due to their widespread uses in many co rod bility to bind to 49 blood -proteins, and long half-life in humans, scientists rout. d PFAS blood and 50 serum of both occupationally and non -occupationally exp people (Kannan 2004, 51 Karrman et al. 2006, Olsen et al. 2003). Both laborato ies using animals an 52 epidemiological studies of human show that expos some P may be associated with a 53 wide range of adverse health effects. 54 2 SITE CHARACTERIZATION TO 55 The fundamental objective of site characten o op_ a accurate picture of the 56 sources of contamination, the contaminant fa nd tr d potential exposures and risks 57 posed by a site. The site charac ' ation tee e d study principles for PFAS-contaminated 58 sites are essentially the sam other ecuted site investigation of any other type 59 of hazardous substance minat ite. Gene ite investigation principles and techniques 60 will not be covered in ct �hee : here are y existing guidance documents about how 61 site investigation shoul this section on characterization, the fact sheet 62 will cover how the unique al characteristics, the unique uses, and the unique transport 63 mechanisms 0 .uld ounted for when characterizing a PFAS contaminated site. 64 2.1 Sotft* s and Site ficati 65 The un.q AS properti including both hydrophobic, lipophobic properties, and stability 66 under extre sical a hemical environments, has resulted in extensive surface coating 67 applications, pr ulations, and industrial uses. (3M, 1999; European Food Safety 68 Authority [EFSA], This widespread use has resulted in widespread contamination of the 69 environment by PFA PFAS contamination is both ubiquitous, creating anthropogenic derived 70 background concentrations in numerous areas around the globe, but also creating many point 71 sources of contamination. At this time (2017) there has not been an extensive accounting of the 72 many uses of PFAS nor has an extensive accounting of all the possible products and industries 73 where PFAS are found been created. The reader is directed to the History and Use fact sheet for 74 information on what is known of the uses of PFAS in the present and the past. Cgailllltt (RDl]: Point to other guidance such as UFP QAPP DEQ-CFW 00069700 75 Notwithstanding the difficulty of knowing where PFAS contamination may be originating from, 76 any investigation of a site starts with review of site chemical use, processes, and history of 77 release of hazardous substance. It is likely the site history with timelines of processes, layouts 78 and chemical use compared against the timeline of PFAS development and use will give clues to 79 the types of PFAS that were released at the site. This is typically done at hazardous substance 80 release sites, however; this process takes on special importance at PFAS contaminated sites. 81 PFAS comes in complex mixtures and those mixtures changed over time. Also, mixtures of 82 PFAS included many different PFAS that have yet to be identified and comp unds for which 83 there are no developed analytical techniques. Even if the techniques are no _ vailable to the 84 research community, they have not been commercialized and standards n do not yet exist. 85 (See the section on Analytical Methods below). Also, the chemicals not have been identified 86 in site documents as the chemicals were thought to be inert and sderstanding of the 87 uses of PFAS and their history is critical to understanding wher AS m ve been released 88 at a site. At a typical site, it is likely that much of the mass P AS contam n will not be 89 measured because the analytical techniques are not yet av ' a le, so during the t'gation a 90 portion of the contamination will go undetected. 91 These facts need to be understood when looking for g arrizing source areas. There is 92 often a focus on only constituents of regulatory concern --ample, PFOS, PFOA and in some 93 cases PFBA and PFNA). However, these chemicals may n lye been in the original mixture, 94 but may be breakdown products of other P :' Additionally, "i ity evaluations of other PFAS 95 are in process at this time and it can be anti othm a _ years many more PFAS will 96 be of regulatory concern. 97 PFAS contamination can be resd to the en ent as a solid, liquid, gas or dust/ash. PFAS 98 movement in the environ 6 t-is`ri'` straightfo like many contaminants. Each PFAS has 99 one end of the molecul at e, esse pally inert 'le the other end of the molecule has been 100 designed for many dif Si1apph The act a end will react with enviromnental media 101 based upon its unique chfen icsftilb?tl perfluorinated end will react in a relatively 102 consistent way. 103 PFAS cogurination o 104 Gomes film secondary sources. Prime examples are the watering of lawnsPFAS contam ated water and application of contaminated biosoilds to farm land. 105 Air depds lion from mdus , _i1 and non -industrial use, burning of PFAS contaminates materials 106 creating P�� contaminatdash, and use of PFAS in transportation related products can lead to 107 non -point sou r6qs An unexpected source of PFAS contamination to the environment is septic 108 fields and mstitifti" Ctuse a great deal of some cleaning products. As a site investigation 109 proceeds and the site=is large in areal extent, it can be expected that these other sources of 110 contamination will be encountered. The Environmental Fate and Transport Fact Sheet includes 111 conceptual site models for different source scenarios. 112 2.2 Geologic and Hydrogeologic Framework 113 Once the likely source or sources of contamination are understood the normal techniques of 114 investigation are followed. Soils at the source are sampled and characterized. Pathways to 115 groundwater and surface water are investigated. Success for these studies, like all such studies, DEQ-CFW 00069701 116 117 118 119 120 121 122 123 124 125 126 127 relies upon an adequate understanding of the geology and hydrogeology of the site. Some HAS are relatively immobile in water. Some PFAS will be dispersed into the air as a gas, dust or ash. Others readily dissolve in water and move with groundwater and surface water. Sediments may act as a sink of PFAS contamination. No natural attenuation can be expected for these contaminants other than dilution. Thus, the plumes of several HAS (for example, PFOA, PFHxS, PFOS) can travel for many miles from the original source, with concentrations above risk based levels of concern. At many sites the PFAS plume will be much more extensive than plumes from other contaminants released at a site. A thorough under4sa f the geology/hydrogeology and hydrology of a site can reduce the requireby making the selection of sampling locations more efficient. The expense of samplltiple mobilizations make PFAS contamination characterization costly and investigation planning is paramount to avoid any unnecessary investigation. 128 Although there numerous large and complex HAS contam' Ti sites, not site will be 129 highly complex. A site may be created by a onetime releldpVent such as tank3M that is 130 extinguished with AFFF. 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 2.3 Risk Assessment The objectives of site characterization and the include enabling decision makers to makethf both humans and the environment and the Figure 1 is a generalized conceptual site mo geologic media such as soils and rock, sedim air. Through any of these im media, hu these contaminants are so ter, site drinking water, either s d from undwa discovered through d ' water v because PFAS plumes tr . R opme accurate site conceptual model decision t risks posed by the site to 1 need t aken to address those risks. S contamination will impact e t often impacts surface water and biota can be exposed. Because many of either discovered because of contaminated surface water. Even if a site is not s frequently tested immediately at many sites not breakdown. The main iss S coNch on and risk assessment is simply the lack of sufficient study on th , zicity o Ss. Almost allof the work to this point in time has been on just S and PFOA. nd link to pathology, of these two compounds is complex and stil ell understo eath Advisories and criteria development has been slow. Given the fact tha AS come i mplex mixtures and the ecological system and in the human population is - ed to a complex mixtures, makes evaluating the true risks as a site very difficult. Some a d oose to only focus on the chemicals that have a regulatory standard or have an issued hea visory. From a technical point of view, this is almost always inadequate to evaluate the risks a site poses. More guidance is needed for risk assessors to be able to provide an accurate assessment to decision makers and the public. Because of the above mentioned challenges, it is incumbent upon the investigation team to identify data gaps and the impact that they have on analysis of risks. Decisions will have to be made with only a partial understanding of the site and risk conceptual site model. Those deficits must be documented so that future researchers can reassess the site and the public can understand that the decisions are made without believing that information is being suppressed. DEQ-CFW 00069702 157 2.3.1 Develop Initial Conceptual Site Model (CSM) 158 2.3.1.1 Human Receptors 159 The numerous sources and types of PFAS chemicals present a special challenge to risk 160 assessment. For example, exposure to PFOA results not just from exposure to PFOA and its 161 precursor compounds in soil and water from releases to the environment, but also from food (for 162 example, beef, vegetables), drinking water, packaging materials, treated carpets and personal 163 care products, among other ubiquitous sources. This means almost every In being has some 164 PFAS exposure. Exposure to PFOA and other PFAS chemicals can also, eur, and may be more 165 significant in occupational settings (for example, PFOS exposure by airy using AFFF, during 166 manufacturing).,, 167 PFOS is also known to bioaccumulate significantly in fish, ing0ding specie" _light for human 168 consumption. Another PFAS exposure scenario involvm ainsitive receptor e to the fact 169 that infants consume more fluid, as breast milk or form and that PFOA concen €ions in 170 breast milk have been detected at similar or higher co) ntratio s than in the mother's drinking 171 water. Serum PFOA levels in infants increase rapid y a er bi -This elevated, early life 172 exposure is of concern, as it can persist for many year ei, the slow rate of chemical clearance 173 from the body. ..". 174 2.3.1.2 Ecological Receptors"- 175 Persistent, bioaccumulative chemicals such aK FFAS 13eirks via direct exposure of 176 individual organisms to contaminant releases w hs to ecosystems via concentration and 177 distribution in the food chaA,�LO�nts to terre ;aquatic and aquatic -dependent species can 178 begin in contaminated s >arld sedi ent, with t estrial and benthic microorganism exposure. 179 This initial loading can %centrate d build up ough primary consumers as they eat plankton 180 or plants, up to and thrrto pretors (Yalding humans), all carrying an increasing body 191 burden in body fluids and tBoth wild and domestic species maybe affected, which has 182 implications forhih a ihealth sk from the consumption of fish, hunted animals and livestock. 183 Little haslieen done wiNf4gard to ecological risk assessment, but laboratory studies of animals 184 and various reports of PFA .levels in wildlife populations give rise to increasing concerns about 185 the impacfito biota. As A-iswriting there is little information on wildlife/ecological studies 186 being done Aor PFAS condminated sites. 187 2.3.2 Risk Assessment Evaluation 188 Although there are many PFAS contaminated site due to fire -fighting chemicals such as AFFF, 189 other everyday products can contain PFAS and serve as secondary sources of contamination. In 190 almost any urban setting where a medium to large size PFAS contamination site exists, 191 encountering other plumes or sources of soil, sediment and surface water contamination of PFAS 192 that are not associated with the site under investigation is likely during the remedial 193 investigation. All PFAS are anthropogenic in origin (maybe some very minor sources in nature). 194 Thus, these other HAS sites or background HAS contamination is anthropogenic in origin. DEQ-CFW 00069703 195 Data analysis needs to be more robust in such situations. Identifying multiple sources may 196 require more reliance upon data analysis techniques not frequently used at other non-PFAS 197 contamination sites. This problem also underlies the need to analyze for the full suite of PFAS 198 chemicals that labs can usually perform Data Analysis and Interpretation. Upon the PFAS data 199 collection, the CSM can be refined by conducting more in depth ratio analysis for individual or 200 families of PFAS and/or isomer identification Forensic chemistry analysis is necessary at larger 201 PFAS contamination sites to differentiate sources and plumes, determine release history and 202 document data gaps in chemical site characterization and risk analysis. 203 Thousands of PFAS have been used in a wide range of consumer produ 'th many of the 204 PFAS being precursors that could partially degrade in the environme iota to other PFAS 205 have been found to be highly stable and persistent end products ( 2017). The ratios 206 of different individual or families of PFAS could indicate how to a 'al source zone 207 the sample was collected; if more than one product that con FAS mig been used, if 208 more than one source might be responsible of the PFAS c ination, and ho nt the 209 release in the environment might have occurred. Also g-chain sorption to soi sediments 210 have been found to be bind more strongly than sho n (Ahr et al., 2010; Higgins and 211 Luthy, 2006; Zhao et al., 2012). As a result, short-ch a expected to travel faster and 212 longer distances from the sources compared to long-cha S (See the Environmental Fate 213 and Transport Fact Sheet). The ratios between different P ould be used to better 214 understand and document how far from a ource a ce ple might have been taken. 215 2.4 Development of Site Cri[teri 216 The lack of regulatory criteria lth advis ns that at certain sites, site -specific 217 chemical criteria will nee oped. Gu ce should be developed for risk assessors on 218 accounting for risks of witho adequate ity data. DEQ-CFW 00069704 219 220 3 SAMPLING 221 3.1 General 222 Sampling conducted for the purpose of determining PFAS compound concentrations in various 223 media and sources is in most ways similar to traditional chemical compounds. However, there 224 are additional considerations and protocol that are specific to PFAS samplin . The applicable 225 local, state, and federal rules and guidelines should be followed unless it 'termined that a 226 particular method or procedure is contrary to the specific needs of a P = sampling program, in 227 which case the applicable agency should be contacted directly to det'.. a mutually beneficial 228 approach or to determine if an exception can be made. The low fiat ,tection limits, state 229 and federal screening levels, and in some cases, cleanup cater `tII or exampl . Pw as) and 230 ubiquitous presence of PFAS compounds in the envit so requires ex pary 231 considerations during PFAS sampling. 232 Caution should be used to avoid direct contact withJngestioii`of sampling media that is 233 potentially contaminated with PFAS. As described in tItIjsry and Use section, various 234 adverse health effects from PFAS compounds are suspecfes <The American Cancer Society has 235 classified the PFAS compound, PFOA as • ossibly carcinog to to humans" (Group 213) as of 236 January 2016, based on limited evidence i ` juts that It can0.testicular and kidney 237 cancer, and limited evidence in lab animals ` ertd'alancer Society [ACS], 2016). 238 3.1.1 Equipment and Supplies 239 Many material used m th Course o 4anvironme ;investigation could potentially or do 240 knowingly contain PF�So far, t >e is no pub died research on how certain materials that 241 may be used by field staf ,effect s p% -re It erefore, a conservative approach is 242 recommended during execut iiib tthe sampling plan. All efforts must be taken to exclude 243 materials that arplatown to contain PFAS compounds. Various sources of PFAS are discussed in `se it<heet 01tain and review all material Safety Data Sheets (SDS) before 244 the Historyt`[T 245 considerifig them for uess&#--. ng PFAS-'sampling. Anything with "fluoro" in the name or the 246 acronyf TPE, FEP, ET ;.and or PFA is suspect PFAS-containing material. Materials typically 247 used in P�sampling prjerts are provided in III(a)(i). 248 fable XX �dentlfibs matenals and equipment commonly used in the course of environmental 249 investigations that arOconsidered appropriate for use in PFAS focused investigations, as well as 250 materials that are known or suspected to be potential sources of PFAS and should be avoided if 251 possible. Further, this section will provide guidance to the environmental professional with 252 respect to what actions to take when a material that is known to or suspected to contain PFAS or 253 could potentially impact the PFAS analytical results (adsorption) cannot be avoided and must be 254 used 255 The ITRC PFAS team recognizes that there can be instances where it may not be possible to 256 completely eliminate the use material that may be able to contribute to or impact the result of 257 PFAS in your samples. These instances could include sites where hazards warrant the use of 258 specific PPE, or where PFAS are a co -contaminant or a secondary contaminant and the primary 7 Comment [YY7LCSL21: Provide link to ITRC Website where table will be maintained and updated as data becomes available. Comment [LH W3R2]: The table should be developed for the team review. As noted by Janice, it can be provided as a separate file from the fact sheet so that it is easily updated. DEQ-CFW 00069705 259 contaminant requires the use of specific materials for proper sampling, or where the opportunity 260 to collect a sample presents itself prior to the establishment of a proper sampling program. In 261 these instances, it may not be possible for the environmental professional to avoid the use of 262 non -ideal or unacceptable material. In these situations, the development and application of a 263 thorough quality assurance and quality control (QA/QC) program is of the utmost importance. 264 3.1.2 Bottle Selection 265 Containers should be provided by the laboratory selected to perform the analyses, and should be 266 certified by the laboratory to be free of the PFAS that are to be quantified. UOPA Method 537, 267 Version 1.1 (September 2009) requires the use of a 250 milliliters (mL) ropylene containers 268 and caps/lids for drinking water sampling. Currently, there is no EPA ance/requirement for 269 bottle selection for any sample media other than drinking water. U 270 guidance/requirement are provided, it is recommended that a hi nsi ethylene (HDPE) 271 with a plastic cap containing no Teflon® liner, be utilized for her medi . 272 When selecting the size/volume of the sample to be col in addition to repre tiveness of 273 the site being considered, best practices in sample pr tion st must be considered as well. 274 All plastic bottles (for example, HDPE, polypropyle en to adsorb PFAS at various 275 rates. In order to minimize this adsorption effect on sa Its, the laboratory must analyze 276 the entire sample and rinse the sample container. The prof eening and/or applicable 277 regulatory levels and the expected/potenti entration o alytes are also relevant. If the 278 sample is known to contain high concentra s (for e le, AFFF formulations), this 279 loss is negligible and therefore the entire s `le o n 1 to a used. Since the 280 concentration level of PFAS in aqueous sam wine whether the whole sample or an 281 aliquot is used in the laborato Aration, i "s ended that a small volume of each 282 sample be collected in a se iner. Th = a ple will allow for the laboratory to screen 283 the sample for high con tions out effe v the final sample result. In the case of soil or 284 sediment, obtaining a ' en— i $ub vnple i .` e laboratory is critical, therefore, the entire 285 sample should be homog prior to subsampling. For these reasons, it is 286 important to coordinate wit 4eaboratory on the appropriate container volume for 287 environmenainedi*tither tharng water. P, 288 3.1.3 J9 ple Preservatt Shipp"g, Storage, and Hold Times v 289 USEPA 81537, Verq 1.1 (September 2009) contains specific requirements for sample 290 preservation, shtppmg s _ ge and hold times. Currently, there is no EPA guidance/requirement 291 for other sampf6e*, ka . or most PFAS samples (non -drinking water) the only preservation 292 needed is thermal.)" I ervatives such as Trizma® are not needed since free chlorine in the 293 media is not expected. EPA guidance/requirements are published or laboratory validated studies 294 are conducted, it is recommended that thermal preservation, shipping, storage, and hold times 295 contained in USEPA Method 537, Version 1.1 (September 2009) be adhered to for all other 296 sample media, with the exception of biota. For biota samples such as fish, it is recommended 297 that the samples be frozen upon receipt at the laboratory until sample preparation. It should be 298 noted however, that current information does not suggest that sample storage above 6°C, or even 299 above 10°C, for a brief period of time (for example, several hours to a few days) renders the 300 results invalid. Perfluoroalkyl substances are resistant to degradation under typical conditions DEQ-CFW 00069706 301 and, if anything, the results could be biased high due to the degradation of precursor compounds 302 to the perfluorinated compounds of current regulatory interest. 303 Note that the ambient water temperature may be higher than 10°C depending on the site location, 304 type of water (for example, surface water, groundwater), and season; the ambient air temperature 305 may also be significantly higher than IOT during the sampling. In addition, in some cases the 306 samples may be hand delivered to the laboratory, rather than being shipped overnight. In these 307 situations, it is important to chill the samples quickly. 308 3.1.4 Decontamination Procedures 309 Sampling equipment should be thoroughly decontaminated before mobilisation to each 310 investigation area and between sample locations at each investigattiigdi6 or as required in the 311 site -specific work plan. Field sampling equipment, including oiUACiter ii orface meters and c 312 water level indicators, and other non -dedicated equipment uscdt each sam location, will 313 require cleaning between uses. Alconox® and Liquinox® is acceptable atse since the 314 Safety Data Sheets do not list fluoro-surfactants as an i lent. Water used fore"f[nal rinse 315 during decontamination of sampling equipment will la6oratorcertified "PFAS free" water. 316 For larger equipment (for example, drill rig and larg tloovnho drilling and sampling 317 equipment), decontamination will be conducted with p1e`ater using a high-pressure washer 318 and then rinsed using potable water. Decontamination of s`6 11 heavy equipment is best conducted 319 within a decontamination facility or other eaus of contai`gnt (for example, bermed, lined pad 320 and sump or a portable, self-contained dec� taiX4tii�t on booth). Ppt6b water sources should be 321 analyzed ahead of time for concentration of ,FAS constitttents, Wherever possible, a "PFAS free" free" water rinse shall be conducted immedia ply predtn the equipment use. 323 3.1.5 Field QC (frequency;}cni,6ri , procedure 324 Field Quality Control sample are a means of assessing quality from the point of collection. 325 Such QC samples include; but are not limited to trip blanks, field blanks, equipment rinse blanks, 326 and Sample Duplicates. They can provide valuable information on the heterogeneity of the 327 media, and possible biases due contamination (for example, insufficient rinsing of sampling 328 cquipment) USEPA iu ethod 53-,, Version 1.1 (September 2009) contains specific requirements 329 for theyleld Quality Coh"l (QC) samples that must accompany drinking water samples. For all pec 330 other sA*le media, the sific field QC samples utilized is dependent on the type of sample 331 media collected, PFAS concentrations expected, and type (for example, single use, resusable, 332 HAS containing) of equipment used. Although the collection and analysis of QC samples adds 333 cost to the sampling and analysis program, these samples can be especially important for PFAS 334 analyses due to thievery low detection limits of the analysis methods and because of the 335 widespread use (historical and current) of fluorinated compounds (including perfluoroalkyl 336 substances and their precursors) in commerce. 337 3.2 Sampling Procedure 338 Sampling a "potable water source", as defined by the EPA Safe Drinking Water Act (Section 339 1401(4), August 1998), is conducted according to protocol established in the USEPA Method 340 537, Version 1.1 (September 2009). Per this method, the drinking water source must be from a DEQ-CFW 00069707 341 public drinking water supply, as opposed to a private drinking water supply for this method to be 342 applicable. 343 Currently, there is no EPA guidance or requirement for other sample media, however, general 344 guides such as ASTM Standard Guide for Sampling Ground -Water Monitoring Wells, D 4448-01 345 (ASTM, 2007), Pore Water Sampling Operating Procedure (EPA, 2013), and the Compendium 346 of Superfund Field Operations Methods (EPA, 1987) are good sources for general information. 347 These standard procedures sampling can be used with some exceptions and/or additional 348 considerations to be taken to address issues associated with the potential use of HAS containing 349 sampling equipment and supplies. Table XX should be consulted to minirrl&lhe use of HAS 350 containing equipment and supplies as well as those with PFAS adsorpti ues. 351 3.2.1 Groundwater 352 The most inert material (for example, stainless steel, silicone igh-dens ethylene), -353 with respect to known or anticipated contaminants in the should be us never 354 possible. Dedicated sampling equipment installed in ex' wells prior to the P 355 investigation should not be used without identifying aterial and within the equipment 356 and reviewing their chemical properties to ensure th PF ee. For longer term 357 investigations, samples may be collected in duplicate ithout existing dedicated 358 equipment. If HAS analyses show that the equipment do mpact results, the equipment 359 may be kept and used long term. Howeve deternminatio pendent upon project -specific 360 requirements and should only be allowed b ee p anager ' -dull disclosure to all 361 stakeholders.: 362 3.2.2 Surface Water 363 Generally, the outside o vappe ple con ers shall be triple rinsed with the surface 364 water being sampled filling containers ss'th the sample to be analyzed. Where required 365 by site conditions, remo ph o ontainers will be allowed by clamping the 366 container onto the end of a xtension ro The extension rod must be made of material that 367 does not me FA3,gnd ha through decontamination. 368 3.2.3 1* Water and HDPE tubing are typically used for pore water sample 369 Peristalticpnnnpstyith sih 370 collection A with pusW*int samplers, pore water observation devices (PODS), and/or drive 371 point piezomet;6 PusJafioint samples and drive point piezometers are construction of stainless 372 steel and inherentl` lac any PFAS-containing material. PODs are constructed of slotted PVC 373 pipe and silicon tubih and will not contribute PFAS to the samples. PODs and drive point 374 piezometers are permanent, or dedicated, sample points typically installed and used for multiple 375 sample events, whereas push point samplers are used for a temporary sampling location. If non- 376 dedicated sampling equipment is to be used and contaminant histories of the sample locations are 377 known, it is advisable to sample in order of the least contaminated area first and sample the area 378 of highest known contamination last. 379 3.2.4 Soil/Sediment 380 10 DEQ-CFW 00069708 381 Core samplers and grab samplers are two types of soil and sediment sampling devices that are 382 typically used. Most of these devices are constructed of stainless steel, and some core samplers 383 allow a sleeve, which should be made of HDPE, to be inserted into the core barrel to retain the 384 sample. PPE may be required for sampling personnel such as waders and personal floatation 385 devices. Ensure that these materials that will come in contact with the sampling media do not 386 consist of water-resistant coatings or other PFAS containing materials or substances. 387 3.2.5 Fish 388 Proper procedures are necessary to assure the quality and integrity of anal ig�l results and that 389 appropriate fish samples are collected according to the project -specific o iives. The species of 390 fish collected as well as the portion of the fish prepared (whole versu et) depends on the 391 project goals (ecological risk vs human health). Studies have sho . z; "AS bioaccumulation 392 rate vary depending on the PFAS studied and the species of fish,. r"dies g also shown the 393 majority of the PFAS bioaccumulated in fish is stored in the o_gns, not the b , Because of 394 this, communication of the project objectives with the ana - 1 laboratory is a n�nportant 395 prior to the field work in order to determine the quanti 'd quality of tissue nec Sry, fish 396 handling requirements, laboratory sample preparati(�i'cludingAingle fish or composite fish 397 samples and whole or fillet preparation), packing an t§l f pin equirements. 398 3.2.6 Potential high concentration samples 399 The conceptual site model (CSM) or prevr6"s s tng may in�Fl to areas of high PFAS 400 concentrations. In these cases, the samples) foul-U- 4 ected'th additional care taken to 401 avoid damage that can occur to laboratory eq j�ment doe tralysis of high concentration 402 samples using standard methods Some proje fs ma eq ire the analysis of AFFF product that 403 has been used at the site. A11� _product sa ples must be considered high concentration s gregated fr other samples during the sampling event as 404 samples. These samples sl&i� be 405 well as during shipmelohi;entrati&is a the laboAlky in ordee'to avoid cross contamination. The samples 406 that may contain high of"AS should be clearly identified on the Sample Chain 407 of Custody (CoC) that is shtpop#'with the samples to the laboratory. Field test kits are available 408 for PFAS compound but have bt been fully evaluated at the time of this Fact Sheet release and 409 cannot achieve low dett(otions limits that may be necessary. However, when such kits become 410 availabjd they could be �i ' helpful`in screening for potential high concentrations of PFAS in 411 the field:-, _ 1- 412 4 ANALYTICAL METHODS 413 4.1 Quantitative 414 USEPA Method 537, Version 1.1 (September 2009) contains specific requirements for sample 415 416 417 preparation and analysis of drinking water samples. Currently, there are no EPA methods the preparation and analysis of other sample media, however, other method have been published. See C able YNI for a list of current published methods for PFAS analysis comment iWJLCSL4l: Link to list of methods on ITRC website -- -- Comment{LHW5R4]: The table should be developed for the 418 The following information is based on current best practices and is recommended until additional team review. As noted by Janice, it can be provided as a separate file from the fact sheet so that it is easily updated. 419 methods are published by the EPA. 11 DEQ-CFW 00069709 420 4.1.1 Sample Preparation 421 Care must be taken to prevent sample contamination during preparation and extraction. All 422 supplies must be checked and confirmed as PFAS-free prior to sample preparation. Intermittent 423 contamination can occur due to vendor supplies or manufacturing changes, therefore it is 424 recommended that each lot of supplies be verified prior to use. 425 Ensuring a representation sample/subsample is utilized by the laboratory for analysis is critical. 426 In order to do this, entire aqueous sample received by the laboratory must be prepared and the 427 sample container appropriately rinsed. Sample filtration is not recommend rice problems 428 with adsorption of PFAS onto filters have been noted. Instead, techniqu ch as centrifuging 429 are often used. Due to limitations in technology (Solid Phase Extract' PE) cartridge 430 capacity and instrumentation sensitivities), the exception to this is ma. ing high 431 concentrations of PFAS. The laboratory should screen the samp ng Illholl volume sample 432 that was received in order to determine if the sample contain S at cone ons too high 433 for SPE sample preparation and analysis. Samples that ar ared using the sample 434 must be extracted using SPE while high concentration es must be prepared serial 435 dilution techniques. For solid samples, the entire sa receiv ust be homogenized and 436 extracted using SPE. In order to account of biases re f eparation steps, internal 437 standards (isotopically -labeled analogs of each analytes, ercially available) should be 438 added to the whole sample/sample aliquot prior to the nex n the process. For samples 439 prepared by serial dilution, internal standa uI I be adde final sample dilution. 440 Clean-up procedures (such as ENVI-Carb T on ch as on samples when matrix 441 interferences (for example, bile salts, gasolin ge n could be present. Clean-up 442 procedures should always be for prep soil, sediment, and biota. ENVI-Carb TM 443 cleanup will remove choli own inte nce in fish sample. 444 Batch QC samples su : ethod _ c ), l iratory control sample (LCS), laboratory 445 control sample duplicate p e (SD), matrix spike (MS), and matrix spike 446 duplicate (MSD) should be ' d based on the type of sample (for example, high 447 concentratio ' bei ared. For sample with high concentrations of PFAS, it is 448 recomme at m ` of ,'r a M3"MSD, a LCSD and SD be prepared. The SD should be 449 prepar in ad cr n ' not from the same sample bottle to create a second set of serial 450 dilutions ; 451 4.1.2 452 The currently the analytical detection method of choice for PFAS analysis is liquid 453 chromatography -mass spectrometry -mass spectrometry (LC/MS/MS), which is especially suited 454 for analysis of the ionic compounds, such as the PFSAs and PFCAs. GCMS can also be used for 455 PFAS analysis, specifically the neutral and nonionic analytes, such as the fluorotelomer alcohols, 456 fluorooctane sulfonamides (FOSAs) and sulfonamidoethanols (FOSEs). Currently, LCMSMS 457 analysis of PFAS is widely commercially available where are GCMS analysis has limited 458 commercial availability. 459 LCMSMS methods developed by laboratories are typically modified versions of USEPA Method 460 537, Version 1.1 (September 2009). The EPA method does not contain steps to alleviate matrix 12 DEQ-CFW 00069710 461 462 463 464 465 466 467 468 469 470 471 472 473 474 475 476 477 478 479 480 interference issues potentially found in other sample media and does not contain steps to prepare solid sample media. Modifications typically include inclusion of such steps, utilization of isotope dilution for more accurate quantification, and the addition of other PFAS analytes to the scope of the method. Because these modifications are not standardized, laboratory modified methods can result in data of greatly varying representativeness, precision, and accuracy. The DoD Environmental Data Quality Workgroup (EDQW) has attempted to standardize a significant number of these modifications through the requirements contained in the DoD Environmental Laboratory Accreditation Program (DoD ELAP) document, the DoD Quality Systems Manual for Environmental Laboratories (DoD QSM), Version 5.1, 4,ppendix B, Table B-15. Chemical standards are available from several manufacturers. Care gt lie taken in product selection as these products may have variable purity and isomer pr at may negatively impact the accuracy, precision and reproducibility of data. Only, ified`�tndards of the highest purity available (for example, American Chemical Society (.) grade) ca used for accurate quantitation. Standard containing linear and branched iso ef5 are not commer . ly vaiiable for all applicable analytes. Currently, such standards a 4rily available for PFOSd PFHxS. Technical grades which contain branched and linear ers are.46ilable for other PFAS. These standards do not have the accuracy needed to pdoquantitation purposes, but can be usefull in verifying the location of branched isomers.tlon of individual HAS should include all isomers. ... 481 Isotope dilution quantitation technique is r v ' t ShdeA Isotope ilution is the technique of 482 quantifying the analytes of interest against t ' isoto iMally lai 10 analogs of the analytes, 483 which are added to the sample prior to and a sam�i reparation. Addition prior to 484 preparation helps to account�for loss of analyt dttrig4the preparation process whereas addition t .,. 485 after preparation to an al�ttot of the sample extract accounts for the bias associated with the 486 instrumentation. 487 Mass calibration should dccur at the frequency recommended by the instrument manufacturer 488 and as needed based, on QC`ttidicators such as calibration verifications. The instrument blanks, 489 calibration curve; initial and cotilinual calibration verification requirements should consistent 490 with those published for_other LCMSMS methods. The lowest calibration point should be a 491 concentration at or below;the limit of quantitation. It is also recommended that a standard at the 492 limit of quantitation concentration be analyzed periodically to document the instrument's ability 493 t&quantitafe eocurately down to that concentration. Instrument blanks are critical in determining 494 if the instrum`ld is potentially biasing PFAS concentrations in samples. Acceptance criteria for 495 all of these analytical QC elements must be set at levels that meet the project's data quality 496 objectives (DQOs).`'For DoD projects, these criteria can be found in the DoD Quality Systems 497 Manual for Environmental Laboratories (DoD QSM), Version 5.1, Appendix B, Table B-15. 498 4.1.3 Data Evaluation 499 Data should be generated from a currently accredited laboratory to ensure the laboratory is 500 capable of performing the analyses required and has a quality management system in place to 501 ensure the data will be generated properly. Industry recognized accreditations include National 502 Environmental Laboratory Accreditation Program (NELAP) or Department of Defense 503 Environmental Laboratory Accreditation Program (DoD ELAP). Evaluation of data generated 13 DEQ-CFW 00069711 504 by a laboratory, even data generated by a certified laboratory, is recommended because 505 accreditation doesn't tell you how well the laboratory performed on your specific samples. The 506 overall quality of the data includes laboratory analytical performance as well as sample 507 collection techniques and complexity of the sample matrix. 508 PARCCS (Precision, Accuracy, Representativeness, Comparability, Completeness, and 509 Sensitivity) parameters should be assessed during the data evaluation. PARCCS guide you 510 through the process of looking at your data (field collection and laboratory information) with a 511 critical eye. Data are reviewed in a systematic way by looking at the results of each Quality 512 Control (QC) indicator of the PARCCS parameters (for example, spike rec 'es, method 513 blanks, etc.) to obtain an understanding about the overall quality of the The most important 514 goal of Data Evaluation is to ensure that you understand whether the any limitations to your 515 HAS data (i.e., confidence that the data are usable to meet your n rder to perform this 516 evaluation you need to know how the samples were collected, t w w there were any 517 problems encountered during collection, and have a report fr e laborato laining how 518 the samples were analyzed, including the sample results a C performance s es. 519 Ideally, before you send samples to a laboratory, you s specify to them exac hat 520 compounds you need, whether there are specific re ry leve concern for the compounds 521 (for example, must meet Vermont Regulatory Limits u want the data reported, or in 522 laboratory terms, what type of "data deliverable" you re ata deliverables range from 523 simple data sheets that report only sample results to "full iverables" containing all sample 524 and QC results with raw data (i.e., ins trum uts). The la ry can also provide your data 525 in a variety of electronic formats (called El elive s or EDDs). At a minimum, 526 we recommend that you request a report tha tain tter (or Narrative) explaining 527 sample receipt, analytical methods, and any ed s data sheets containing results for 528 compounds and method QC - urrogat ries). With this simple deliverable, you 529 will be able to assess PA o ide con ce in the data. 530 For large public projec uali 3 Prct Plan (QAPP) such as Intergovernmental 531 Data Quality Task Force, . for Quality Assurance Project Plans, 532 Optimized UFP- Wor - s (March 2012) 533 [https:// /pro pn/files/documents/ufp_gapp_worksheets.pdfJ will specify 534 the proje - uiremen demo tion and documentation of Data Quality Objective 535 (DQO - the PARCCameters: If developing a QAPP is not feasible, the Consolidated 536 Quality 4 s Manual ( v1) for Environmental Laboratories, Version 5.1 (DOD/DOE, 2017) 537 [http:// ` ` osd.mi edgw/documents/documents/qsm-version-5-1-final/] outlines standard 538 protocols for c ettng d performing analysis of samples for PFAS. Table B-15 of the QSM 539 5.1 can serve as t r=j i laboratory scope of analysis for samples when negotiating cost and 540 placing sampling ki orders. Table 13-15, with its specifications of quality control criteria, can 541 also serve as a guide for your evaluation of data. 542 4.2 Qualitative Analysis 543 Several methodologies have been developed that attempt to assess a broader range of the PFAS 544 contamination at a site. These methodologies attempt determine either total precursor content or 545 total fluorine instead of quantifying concentrations of specific individual compounds. Such 546 methods are not standardized through a published EPA method therefore they are not widely 547 commercially available and to date have not undergone multi -laboratory validation. Such 14 DEQ-CFW 00069712 548 methods include Total Oxidizable Precursors (TOP), Adsorbable Organic Fluorine (AOF) or 549 Combustion Ion Chromatography (CIC) or AOF/CIC and Proton Induced Gamma -ray Emission 550 (PILE). 551 5 REFERENCES 552 <currently a separate file ITRC SCSA Fact Sheet References(6-12-17).doc> 15 DEQ-CFW 00069713