I need to assess if I have PFASs contamination at my site. Where do I start?

As the State and Federal regulatory environment for PFASs evolves, we find that more and more facilities are being asked to conduct a Preliminary Assessment of potential PFASs impacts on their site. The primary objective of a Preliminary Assessment is to evaluate whether further investigation or monitoring is warranted given the observed extent, if any, of environmental PFAS contamination in site media such as groundwater and soil. Preliminary Assessments typically consist of a few steps. First, a conceptual model of potential PFASs impacts and sources must be established. Once complete, a sampling campaign targeting those areas and environmental media is developed and executed. Not all PFASs present at any given site are a result of facility operations; while developing the sampling campaign it is recommended to also consider the possibility of PFASs migration from off-site and to collect samples accordingly. Typical regulatory requirements for PFASs Preliminary Assessments are limited to a handful of common PFASs. However, we at Leppert Associates find that it is typically in our clients’ best interest to request laboratory analysis of all forty (40) PFASs that can be assessed using the laboratory method 1633 currently recommended by the United States Environmental Protection Agency for non-drinking water PFASs analyses. Laboratory data would then be reviewed, validated, and compiled into a report for submission to the regulatory body.

What happens next depends on the regulations that the facility operates under and the results of the Preliminary Assessment. In some cases, the investigation ends here: either no PFASs were detected or, more likely, PFASs were either detected at concentrations that pose little to no risk to human health and the environment or the detected PFASs cannot be definitively tied to facility operations. In other cases, the Preliminary Assessment results may indicate that more information is needed to establish PFASs sources and responsible parties. The Preliminary Assessment is intended to be purely observational in nature, therefore the assessment does not typically provide enough data to draw conclusions regarding the potential sources of PFASs impacting the site nor the extent of PFASs migration from the facility in question. Should the Preliminary Assessment indicate that these are questions of concern, a more thorough site characterization or the development of a routine monitoring program may be prescribed.

Written by: Aaron Engers, MS Hydrologist