Highlights from the NYSDEC Part 375 Remedial Program Document
In January of this year (2020), the NYSDEC published guidelines for sampling and analysis of PFAS compounds. In October, the NYSDEC issued an updated version of that document entitled “Sampling, Analysis, and Assessment of Per- and Polyfluoroalkyl Substances (PFAS). The guidance further expanded on the originally published guidelines from January.
The guidance was developed to provide a framework for evaluating the presence of PFAS compounds in the environment under the NYSDEC Part 375 remedial programs and addresses field sampling procedures, laboratory analysis and reporting, data assessment and site applicability. Sampling and testing in the following media are explained in detail: soils, sediments, and solids, groundwater, surface water, drinking water (private wells), and fish.
Following are some highlights of the newly released document.
- The list of 21 compounds that the NYSDEC identified in early 2018 has not changed for routine analysis. However, the actual list of compounds could vary on a case by case basis depending on historic site information.
- PFOA and PFOS are the only compounds that the NYSDOH certifies laboratories for under the drinking water program by EPA Method 537, 537.1, ISO 25101, or Method 533. Method 533 was added since the publishing of the original guidelines in January of 2020.
- Reporting limit requirements still remain applicable to only these two compounds. (2 ng/L for aqueous samples and 0.5 ug/Kg in soil).
- As in the previous version from January, SPLP (soil) and Total Oxidizable Precursors (TOP) (soil/water) analyses could be suggested for some applications.
- Additional analysis may also be required in order to determine the soil chemistry characteristics to support the development of site specific cleanup objectives using the SPLP procedure.
- Water samples that exhibit concentrations of PFOA and PFAS above 100 ng/L (ppt) or the total concentration of the 21 compounds above 500 ng/L (ppt) should be considered for further evaluation.
- The guidelines also now call out guidance values for PFOA and PFAS in soil pending the development of Soil Cleanup Objectives. Results for PFOA and PFAS in Imported Soil are to be evaluated and compared to the corresponding appropriate Guidance Values for Anticipated Site Use. Exemptions may apply based on the results of subsequent SPLP testing and approval by the department. However, in any case, if the concentrations of PFOA and PFOS in the SPLP leachate are above 10 ppt (MCL for NYSDOH Drinking Water),the material is not acceptable for import.
Quality Assurance Project Plans
Specific guidelines for the development of a Quality Assurance Project Plan are included in the newly released guidance document. General requirements follow guidelines published in DER-10, but PFAS specific guidelines are also detailed. NYSDEC ASP Category B deliverables are required as well as a Data Usability Summary Report (DUSR). The DUSR is not required for Imported Fill results.
The guidance provides a detailed explanation of sampling protocols for all of the environmental media mentioned previously. The document also includes guidance on analytical method performance and QA/QC as well as the evaluation and review of laboratory data for non-potable water and solids.
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