HomeMy WebLinkAbout19E - WATER QUALITY REPORTREQUEST FOR
COUNCIL ACTION
CITY COUNCIL MEETING DATE:
MAY 21, 2019
TITLE:
RECEIVE AND FILE
REPORT ON WATER QUALITY
{STRATEGIC PLAN NO. 5}
CLERK OF COUNCIL USE ONLY:
APPROVED
❑ As Recommended
❑ As Amended
❑ Ordinance on 1$' Reading
El Ordinance on 2ntl Reading
❑ Implementing Resolution
❑ Set Public Hearing For
CONTINUED TO
FILE NUMBER
CITY MANAGER
RECOMMENDED ACTION
Receive and File Water Quality Report.
DISCUSSION
The City's Water Resources Division provides potable drinking water for all of the City's residents
and businesses, delivering an average of 30 million gallons each day. In order to accomplish this,
the City owns and operates a water system that consists of 480 miles of pipe, 22 groundwater
wells, 4 pressure control stations, 7 import water connections, 7 water booster stations and 8
reservoirs, and 45,000 metered service connections.
The City publishes an annual report on the quality of the water served to all residents. The water
quality served by the City has always exceeded all established enforceable water quality standards
set by both Federal and State governments. Just recently, and as a result of monitoring water
supplies under the Unregulated Contaminant Monitoring Rule phase three (UCMR3) monitoring
regulations, the State and Federal regulatory communities have become concerned with two
potential chemicals, namely perFluorooctanesulfonic acid (PFOS) and perflurooctonaoic acid
(PFOA) in the groundwater. Both chemicals are part of a family of chemicals known as per- and
polyfluoroalkyl substances (PFAS). Scientific studies of these chemicals indicate that exposure to
PFAS can lead to significant health effects, especially in women who are pregnant or likely to
become pregnant and in children.
UCMR3 testing showed that none of these chemicals have been found in the City of Santa Ana
water wells. However, the State Water Resources Control Board (SWRCB) requested that
additional monitoring (sampling and testing) be conducted on one of the City's water wells as part
of a state-wide monitoring mandate.
The reason for selecting one particular City well for additional monitoring was based on the
proximity of the well to others not owned by the City that have the potential to test positive for the
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Receive and File Report on Water Quality
May 21, 2019
Page 2
chemicals. Wells in the Santa Ana River recharge area have tested positive for these two
chemicals. PFAS are a diverse family of manmade chemicals resistant to heat, water, and oil that
have been used for decades in hundreds of industrial applications and consumer products such as
carpeting, apparel, upholstery, food paper wrappings, fire -fighting foams and metal plating. PFOS
was voluntarily phased out of production in the U.S. between 2000 and 2002. PFOA, and chemicals
that degrade to PFOA, have been phased out from emissions and products in 2015. PFAS are
very stable and resistant to water and grease. For a while, and during the UCMR3 monitoring period
from 2012 through 2015, reliable analytical methods to test for PFAS had high detection limits, as
the analytical methods used were considered screening tools. However, due to advancement in
detection technology, these chemicals are now being reliably detected at much lower levels. Just
recently, the OCWD laboratory has gained accreditation of the most reliable and sensitive method
by the state to run samples on a large scale.
In California, the SWRCB requested that many large water suppliers test for PFAS. Statewide, 612
wells are required to be tested. On March 15, 2019, the SWRCB officially, in a Compliance Order,
requested that the City sample Well 38. The City was directed to sample the well on a quarterly
basis for one year, with the first sample to be collected before June 30, 2019.
Although no enforceable Maximum Contaminate Level (MCL) exists for the two major PFAS
compounds, California has adopted Interim Notification Levels of 14 parts per trillion (14 ng/L) for
PFOA and 13 parts per trillion (13 ng/L) for PFOS. The United States Environmental Protection
Agency (USEPA) has also issued an Advisory Response Level of 70 ng/L for the sum of both PFOS
and PFOA. A nanogram is also known as a "part -per -trillion" and one nanogram per liter is the
equivalent of four grains of sugar dissolved in an Olympic -sized swimming pool.
Exceedance of the Notification Level requires the water system to inform the water system's
governing body, and the governing body of any local agency whose jurisdiction includes areas
supplied with drinking water by the water system. When the Notification Levels are exceeded, the
SWRCB recommends that the source be removed from service and treated. When the Response
Level is exceeded, and concentrations cannot be reduced below the USEPA Health Advisory Level,
SWRCB recommends removing the source from service. Notification Levels are precautionary
health -based advisory levels established by SWRCB Division of Drinking Water, while further
research and analysis are conducted by the state to determine the necessity of setting an
enforceable drinking water MCL. The state Notification Levels are based on the most sensitive
known health endpoints for these compounds: lifetime cancer risk, liver toxicity, and
immunotoxicity.
The March 15, 2019 Compliance Order issued by the SWRCB; USEPA's PFAS Action Plan; and
the State of California Media Release on Guidelines for testing and reporting on PFOA and PFOS
in Drinking Water are included as Exhibits 1, 2 and 3.
The quality of the City's water supply is one of the most important tasks of the Water Resources
division, and the goal is to continue to keep Council informed of the progress of this very critical
water quality issue.
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Receive and File Report on Water Quality
May 21, 2019
Page 3
STRATEGIC PLAN ALIGNMENT
Approval of this item supports the City's efforts to meet Goal #5 — Community Health, Livability,
Engagement & Sustainability.
ENVIRONMENTAL IMPACT
There is no environmental impact associated with this action.
FISCAL IMPACT
There is r)b fipcal impact associated with this action.
0
Fuad Swei, PE, PLS
Executive girector
Public Wor s Agency
FS/NS/RR
Exhibits: 1. March 15, 2019 SWRCB Order
2. EPA's PFAS Action Plan: A summary of Key Actions
3. SWRCB Media Release
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19E-4
State Water Resources Control Board
Division of Drinking Water
March 15, 2019
System No. 3010038
Mr. Nabil Saba
Water Resources Manager
City of Santa Ana
220 South Daisy Ave. Bldg A
Santa Ana CA 92703
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ORDER NO. 05 08 19M 011 3010038
HEALTH AND SAFETY CODE SECTION 116400 ORDER REGARDING SAMPLING FOR
PERFLUOROOCTANOIC ACID("PFOA")IPERFLUOROOCTANESULFONIC ACID ("PFOS")
Dear Mr. Saba:
Enclosed is Order No. 05_08 19M 011_3010038 (hereinafter "Order") issued by the State
Water Resources Control Board ("State Water Board"), Division of Drinking Water ("DDW") to
City of Santa Ana. Please note that there are legally enforceable requirements associated
with this Order.
The contamination of drinking water systems with per- and polyfluoroalkyl substances ("PFAS")
has become an increasing concern due to the tendency of PFAS to accumulate in groundwater.
Scientific studies indicate that exposure to PFAS can lead to significant health effects,
especially in women who are pregnant or likely to become pregnant and in children. Of all PFAS
compounds, PFOS and PFOA have been the most extensively produced and studied in the
United States. Additional targeted testing needs to be completed to further identify the
magnitude of the potential issue here in California.
From 2013 to 2015, the federal Third Unregulated Contaminant Monitoring Rule required all
large water systems (water systems serving over 10,000 people) to collect and analyze more
than 12,000 drinking water samples for PFOS and PFOA. In addition, some water systems
serving less than 10,000 people reported approximately 400 drinking water results for PFOS
and PFOA.
In May 2016, the United States Environmental Protection Agency (U.S. EPA) issued a lifetime
health advisory for PFOS and PFOA for drinking water advising municipalities that they should
notify their customers of the presence of levels over 70 parts per trillion of total combined PFOS
and PFOA in community water supplies. U.S. EPA recommended that the notification of
customers Include information on the increased risk to health, especially for susceptible
populations.
E. JOAOUIN Esn UIVEL, CHAIR i EILEEN SOBECK, EXECUTIVE DIRECTOR
2 MacArthur Place Suite 150, Santa Ana, CA 92707 i www.waterboards.ca.gov
EXHIBITI
t„T RECYCLED PAPER
19E-5
Mr. Nabil Saba - 2 - March 15, 2019
The California Office of Environmental Health Hazard Assessment (OEHHA) recommends
interim notification levels for PFOA (based on liver toxicity, as well as cancer risks) and for
PFOS (based on immunotoxicity). Accordingly, on July 13, 2018, after independent review of
the available information on the risks, DDW established notification levels at concentrations of
13 parts per trillion for PFOS and 14 parts per trillion for PFOA. These levels are consistent with
OEHHA's recommendations.
Pursuant to Health and Safety Code section 116400, DDW is issuing the enclosed Order
requiring testing for PFOA and PFOS along with all additional analytes using in the approved
DDW testing methodology. As specified in the enclosed Order, your drinking water system
sources that are specifically listed in the order are at risk for potential contamination by PFAS
due to its proximity to adjacent facilities known to use, produce, or store PFAS. Additional
information is provided at:
http://waterboards. ca.gov/ofas
Any person who is aggrieved by this Order may file a petition with the State Water Board for
reconsideration of this Order. Information regarding filing petitions may be found at:
http://www.waterboards.ca.gov/drinking water/programs/petitions/index.shtml
DDW appreciates the hard work of the City of Santa Ana in maintaining safe drinking water at all
times. The information gathered from the enclosed Order will assist the State Water Board in its
mission to protect water resources and to address risks to health caused by PFAS in drinking
water.
In early April, DDW will provide a webcast training to provide additional information, share
guidance, and answer questions. Details will be sent as the training develops.
If you have any questions regarding this matter, please contact me at 714-558-4706, or at
Ashley. Dummer(c waterboards.ca.gov.
Sincerely,
Ashley Dummer, P.E.
Acting District Engineer
Santa Ana District
Enclosures: 1) PFAS Sampling Order 05 08 19M_011_3010038
2) Appendix 1: DDW Drinking Water Sample Collection for Per and
Polynuorinated Alkyl Substances (PFAS) Sampling Guidance
19E-6
Mr. Nabil Saba - 3 - March 15, 2019
Cc: Anthony Martinez
Orange County Health Care Agency
Lauren Robinson-- .--
Orange County Health Care Agency
Patrick Versluis
Director of Water Quality, Orange County Water District
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19E-8
Order No. «Order Non 3010038
STATE OF CALIFORNIA
STATE WATER RESOURCES CONTROL BOARD
DIVISION OF DRINKING WATER
Name of Public Water System: City of Santa Ana
Water System No: 3010038
Attention: Mr. Nabil Saba, Water Resources Manager
Issued: March 15, 2019
ORDER REQUIRING CITY OF SANTA ANA TO SAMPLE FOR
PERFLUOROOCTANOIC ACID("PFOA")IPERFLUOROOCTANESULFONIC ACID ("PFOS")
CALIFORNIA HEALTH AND SAFETY CODE SECTION 116400
The State Water Resources Control Board ("State Water Board"), acting by and through
its Division of Drinking Water ("Division"), hereby issues Order No.
05_08_19M_011_3010038 (hereinafter "Order) pursuant to section 116400 of the Health
and Safety Code to City of Santa Ana as set forth below:
AUTHORITIES
1. Health and Safety Code section 116400 authorizes the State Water Board, if it
determines that a public water system is subject to potential contamination, to
order a public water system to conduct periodic water analysis in accordance with
conditions specified by the State Water Board. Section 116400 specifies that the
19E-9
Order No. «Order_No»_3010038
water analysis shall be reported on a quarterly basis unless the State Water Board
finds that reasonable action requires either more or less frequent analysis.
2. On July 13, 2018, pursuant to Health and Safety Code section 116455, the State
Water Board: (1) established a notification level for perfluorooctanoic acid
("PFOA") at 0.000014 mg/L, and specified EPA Method 537 Rev. 1.1 as the
analytical method; (2) established a notification level for perfluorooctanesulfonic
acid ("PFOS") at 0.000013 mg/L, and specified EPA Method 537 Rev. 1.1 as the
analytical method; and (3) established the response level for both PFOA and
PFOS, combined, at 0.000070 mg/L.
3. Health and Safety Code section 116455 requires that within 30 days of a confirmed
detection of a contaminant found in drinking water delivered by a public water
system for human consumption that is in excess of a notification level set by the
State Water Board, the public water system which supplies water directly to the
end user shall notify the public water system's governing body and the governing
body of any local agency whose jurisdiction includes areas supplied with drinking
water by the water system. A local agency means a city and/or a county. If the
water system is a water company regulated by the California Public Utilities
Commission ("Commission"), then the water system shall also notify the
Commission.
4. The drinking water system source specifically listed in this Order is at risk for
potential contamination by per- and polyfiuoroalkyl substances (PFAS) due to
proximity with adjacent source wells which are known to be contaminated with
PFAS, as identified by testing conducted under the federal Third Unregulated
Contaminant Monitoring Rule.
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Order No. «Order_Non_3010038
FINDING
Therefore, for the reasons set forth above, the State Water Board determines that City of
Santa Ana is subject to potential contamination from PFOA/PFOS.
DIRECTIVES
THEREFORE, the State Water Board hereby orders that the City of Santa Ana conduct
periodic water analysis of PFOA/PFOS as follows:
1. On or before June 30, 2019, collect a sample from the following source to be
analyzed for PFOA and PFOS. Samples shall be collected at least once each
alendar quarter thereafter, and not less than for 4 quarters.
Source Number Source Name
3010038-039 Well 38
2. Samples collected pursuant to Directive 1 shall be analyzed using a laboratory
accredited by the California Environmental Laboratory Accreditation Program
(ELAP) for analysis of PFAS using either EPA Method 537.1 or EPA Method 537
Revision 1.1. The laboratory should conduct a complete analysis'for all PFAS
analytes under the method for which it is accredited. For EPA Method 537, Rev.
1.1, analysis for 14 analytes should be conducted. For EPA Method 537.1,
analysis for 18 analytes should be conducted.
3. Due to concerns regarding contamination of samples by PFAS which may be
present in clothing worn, fabric, lotions, sunscreen, food wrappers, etc., extra
precaution must be used when collecting samples to avoid false positive results.
You must consult with your laboratory to ensure that appropriate sampling protocol
is followed. An example sampling protocol for PFAS developed by the Division is
attached to this Order.
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Order No. «Order No»_3010038
4. If laboratory analysis detects the presence of PFOA and/or PFOS in any sample
above the notification levels, City of Santa Ana will have an option to conduct a
confirmation sample within 30 days of being notified of the result by the laboratory.
If a confirmation sample is collected and analyzed, all results will be averaged
within that quarter to determine if the confirmed detection is greater than the
notification level. A result below the laboratory method reporting limit will be
assigned a value of zero when averaging. If a confirmation sample is not collected,
notification pursuant to Health and Safety Code section 116455 is required.
5. If a positive result for a source is followed by a result less than the laboratory
method reporting limit, a second confirmation sample may be taken by City of
Santa Ana within 14 days of the first repeat sample. A positive initial result will be
disregarded if two additional samples do not show the presence of the organic
chemical, pursuant to title 22, section 64445.1, subd. (c)(1) of the California Code
of Regulations.
6. Notification pursuant to Health and Safety Code section 116455 is required if,
following the sampling and testing protocols set forth above, there is an
exceedance of the notification levels for PFOA and/or PFOS in any of the listed
source waters.
7. Notification pursuant to Health and Safety Code section 116455 is not required if,
following an exceedance of notification levels for PFOA and/or PFOS, City of Santa
Ana submits testing results following the sampling and testing protocols set forth
above which shows that, following blending with another source or treatment, the
water delivered to the customer does not exceed the notification levels for PFOA
and/or PFOS.
8. The results of all analyses conducted pursuant to this Order shall be reported to
the Board by the analyzing laboratory using the EDT (Electronic Data Transfer)
process in accordance with section 64469 of title 22 of the California Code of
19E-12
Order No. 05_08_19M_011_3010038
Regulations. Analytical results shall be reported no later than the 10th day of the
month following completion of the analysis.
The State Water Board reserves the right to make modifications to this Order as it may
deem necessary to protect public health and safety. Such modifications may be issued
as amendments to this Order and shall be effective upon issuance.
SEVERABILITY
The directives of this Order are severable, and City of Santa Ana shall comply with each
and every provision thereof notwithstanding the effectiveness of any provision.
FURTHER ENFORCEMENT ACTION
The California Safe Drinking Water Act authorizes the State Water Board to issue a
citation or order with assessment of administrative penalties to a public water system for
violation or continued violation of the requirements of the California Safe Drinking Water
Act or any regulation, permit, standard, citation, or order issued or adopted thereunder
including. The California Safe Drinking Water Act also authorizes the State Water Board
to take action to suspend or revoke a permit that has been issued to a public water system
if the public water system has violated applicable law or regulations or has failed to comply
with an order of the State Water Board, and to petition the superior court to take various
enforcement measures against a public water system that has failed to comply with an
order of the State Water Board.
Sean McCarthy, P.E.
South Coast Section Chief
State Water Resources Control Board
Division of Drinking Water
19E-13
Date
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Order No. «Order Non_3010038
Appendix (1): Division Drinking Water Sample Collection for Per and Polyfluonnated
Alkyl Substances (PFAS) Sampling Guidance
Certified Mail No. 7009 2250 0000 8391 7162
19E-15
19E-16
Appendix (1)
Division Drinking Water Sample Collection for Per and
Polyfluorinated Alkyl Substances (PFAS) Sampling Guidance
19E-17
19E-18
002
Water Boards
DRINKING WATER SAMPLE COLLECTION FOR
PER AND POLYFLUORINATED ALKYL SUBSTANCES (PFAS)
SAMPLING GUIDANCE
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Photo by Valerie Gregory
STATE WATER RESOURCES CONTROL BOARD
DIVISION OF DRINKING WATER
March 2019
19E-19
TABLE OF CONTENTS
I. INTRODUCTION...........................................................................
II. PURPOSE OF SAMPLING GUIDANCE ........................................
III. QUALITY CONTROL FIELD SAMPLE TYPES ...........................
FIELDBLANK...................................................................................
TRIPBLANK.....................................................................................
IV. SAMPLING ACTIVITIES............................................................
AVOID SAMPLE CONTAMINATION.................................................
BEFORESAMPLING........................................................................
SAMPLE COLLECTION PRECEDURE.............................................
AFTERSAMPLING...........................................................................
SAMPLE SHIPPING..........................................................................
ATTACHMENTA...................................................................................
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i
..................................... 1
..................................... 2
..................................... 2
..................................... 2
..................................... 3
..................................... 3
..................................... 4
..................................... 4
..................................... 5
..................................... 6
................................... 7
DRINKING WATER SAMPLE COLLECTION FOR
PER AND POLYFLUORINATED ALKYL SUBSTANCES (PFAS)
SAMPLING GUIDANCE
I. INTRODUCTION
Obtaining representative samples and maintaining their integrity are critical elements of any
monitoring program. Analytical methods may be standardized but the results of analyses are
only as good as the sampling and the sample preservation methods. Sampling is the first key
element in a monitoring program that must be performed properly to assure valid data. The goal
of this sampling guidance is to present the steps for drinking water sampling on per and poly -
fluorinated alkyl substances.
Per- and polyfluorinated alkyl substances (PFAS) are a large group of synthetic fluorinated
chemicals widely used in industrial processes and consumer products. These synthetic
compounds are very persistent in the environment. People are exposed to these compounds
through food, food packaging, textiles, electronics, personal hygiene products, consumer
products, air, soils, and drinking water. Studies indicate that continued exposure to low levels of
PFAS may result in adverse health effects.
California water utilities tested drinking water supplies for perfluorooctanic acid (PFOA) and
perfluorooctanesulfonic acid (PFOS) between 2013 and 2015, as required by United States
Environmental Protection Agency (USEPA) under the third Unregulated Contaminant Monitoring
Rule (UCMR3). In May 2016, the USEPA issued a lifetime health advisory for PFOS and PFOA
in drinking water, advising municipalities that they should notify their customers of the presence
of levels over 70 parts per trillion (ppt) of total combined PFOS and PFOA in community water
supplies. USEPA recommended that the notification of customers include information on the
increased risk to health, especially for susceptible populations. On July 13, 2018, the State
Water Resources Control Board's Division of Drinking Water issued a drinking water notification
level (NL) of 14 ppt for PFOA and a NL of 13 ppt for PFOS due to liver toxicity and cancer risks
(for PFOA) and immunotoxicity risks (for PFOS).
The collection of PFAS drinking water data can support future regulatory determinations and
other actions to protect public health. The analytical methodologies used to assess the PFAS in
drinking water are EPA Method 537.1 (released in November 2018), and EPA Method 537
Revision 1.1 (2009). These are the only methods validated by the USEPA and acceptable to the
Division of Drinking Water for drinking water analyses.
II. PURPOSE OF SAMPLING GUIDANCE
Due to the prevalent nature of PFAS in commonly used sampling materials and personal
protective equipment, as well as in clothing, food packaging and personal care products, careful
procedures must be implemented to prevent contamination of a field sample. The detection of
19E-21
PFAS Sampling Guidance
PFAS at the low concentrations that pose a health risk requires careful planning, sampling and
shipping techniques that ensure the integrity of the sample. This sampling guidance provides
recommendations to reduce such contamination sources and provides information for samplers
to ensure collection of a valid sample. Results from sampling of drinking water sources should
be reported electronically by the analyzing laboratory to the Division of Drinking Water.
III. QUALITY CONTROL FIELD SAMPLE TYPES
Due to the low detection limits of PFAS in the drinking water, the Division of Drinking Water is
specifying the use of both a field blank and trip blank. These special quality control sample
techniques must be discussed with the laboratory to ensure proper sample containers and
materials are on hand when sampling begins in the field.
FIELD BLANK
A field blank is analyzed to assess the potential for PFAS contamination being introduced
during the sampling process and consists of a sample bottled filled at the sample site using
reagent water provided by the laboratory. The field blank must be collected at each sample
site and stored in the ice chest used to store and transport samples. The laboratory will
provide the field blank sample bottle, the reagent water and the preservative (if not already
added to the sample bottles).
Field Blank Procedure: At the sampling site, the sample personnel must open the field
blank sample bottle, pour the reagent water into the sample bottle, seal and label this
bottle as the field blank. Record the field blank identification number on the chain of
custody (COC) form.
This sample is shipped back to the laboratory along with the site samples. The empty
container that the field reagent water was poured out of must also be shipped back to the
laboratory in the same shipment.
TRIP BLANK
This sample is to evaluate potential contamination from sample shipping and handling
procedures. At least one trip blank per ice chest is required.
The laboratory will provide the trip blank. Carry the trip blank as received from the laboratory
to the field site. Do not open the trip blank but place it in the ice chest with the water
samples collected and submit to the laboratory for analysis along with the field -collected
samples. Record the trip blank identification number on the COC.
19E-22
PFAS Sampling Guidance
IV. SAMPLING ACTIVITIES
Become thoroughly familiar with sample collection and shipping requirements before proceeding
to the site to collect water samples. Ensure adequate sample containers are on hand to sample
each site, including the trip blank and one field blank per site.
Keep clear and precise written field records. Implement the methods described in this
document conscientiously and consistently. Departure from these procedures requires
documentation in the field notebook.
All samples shall be collected directly from a sample tap on the well discharge line, with the well
operating and at a location prior to any treatment. The well should be flushed to waste at least
15 minutes before sample collection.
Use of a laboratory accredited to analyze for PFAS using EPA Method 537.1 or EPA Method
537 Revision 1.1 is required for samples reported to the Division of Drinking Water. A list of
laboratories accredited by the California Environmental Laboratory Accreditation Program
(ELAP) can be found at this internet site:
httos://www.waterboards.ca.gov/drinking water/certlic/drinkinowater/PFOA PFOS.html
AVOID SAMPLE CONTAMINATION
PFAS compounds are detected at very low levels (parts per trillion). Therefore, there could
be materials used by the sampler, or present at the sampling site, that could contaminate
the sample. All persons involved in the sampling event should refrain from the use of the
following products at least 24 hours prior to the sampling event and until the samples
have passed to the next person in the COC:
• Do not use 24 hours prior to sample event:
o Cosmetics, moisturizes, sun blocks, fragrances, creams, or other personal care
products (including hair products)
o Pre-packaged food, fast food or items wrapped in aluminum foil
o New or unwashed clothing
o Clothing washed with fabric softeners or dried with anti -static sheets
• Other items that are likely to contain PFAS and need to be avoided include:
o Teflon@ and other fluoropolymer containing materials
o Glass bottles, waterproof /treated paper on field notebooks
o Waterproof markers (such as Sharpie@, etc.)
o Adhesive paper products (such as Post -It @Notes or scotch tape)
19E-23
PFAS Sampling Guidance
o Synthetic water-resistant/or stain -resistant materials (such as waterproof clothing
and shoes such as Gore-Tex), waterproof or coated Tyvek® material (special
attention to boots)
o Sealable bags (e.g., zip -lock ® plastic bags) that are not provided by the laboratory.
(Note: only ultra -clean polypropylene or HPDE material sealable bags are allowed)
• Avoid sampling during rain if possible (if necessary please use, vinyl or PVC rain gear)
• Fill gasoline in the vehicle the day before sampling
• Never eat, drink or smoke during sampling activity
BEFORE SAMPLING
• Complete materials and supplies checklist (Attachment A).
• Familiarize yourself with each site being sampled.
• Coordinate the sampling event with the accredited laboratory. The laboratory will provide
containers, sample preservation, COC forms, Ice chest, quality control samples, and
shipping instructions.
• Bottles should be labeled before sample collection.
• Ensure sufficient number of sample battles and preservatives before departure. It is
recommended to request extra bottles, in case of damage to bottles during shipping or
handling during the sampling event.
• Ensure that the ice chest interior is clean.
• Fill the Ice chest with wet ice (not dry ice, blue ice or reusable chemical ice) before
departure for the sample collection event. Keep water drained from ice chest to avoid
soaking the containers.
• Ensure an adequate number of sealable bags are available to store all sample bottles.
SAMPLE COLLECTION PRECEDURE
• Sampling taps and plumbing should be free of materials containing Teflon® (such as
Teflon® tape at plumbing joints).
• Wash hands with Alconox O soap and deionized water before each sampling event.
• Wear nitrile gloves while filling and sealing the sample bottles, using a new pair of nitrile
gloves with each sample.
• Samples must be collected in a wide mouth 250 mL polypropylene bottle (provided by
the laboratory) fitted with a polypropylene screw cap.
• Each bottle needs to be preserved before sample collection with 5 g/L Trizma®, unless
the preservative has been added to the bottles by the laboratory.
0
19E-24
PFAS Sampling Guidance
• Ensure that the sample container is labeled appropriately, check that the label ID
number on the sample container matches the COC form.
• Collect the sample:
o Open the sample tap and allow the system to flush until the water temperature has
stabilized, or until a minimum of one well casing volume has been flushed out. It is
recommended that wells be allowed to flow for a minimum of 15 minutes before
sampling to ensure that the sample reflects the water quality of the source.
o Reduce the flow to a slow laminar stream to reduce air entrainment and overfilling of
the bottle.
o Uncap the sample bottle. Do not place the bottle cap on any surface when collecting
the sample, and avoid all contact with the inside of the sample bottle or its cap.
o Fill sample bottle, taking care not to flush out the sample preservation reagent.
Samples do not need to be collected headspace free, but a volume of 250 mL is
necessary for the sample analysis.
o After collecting the sample, cap the bottle and gently agitate by hand until
preservative is dissolved.
o Place the sample bottle(s) in an individual sealed plastic bag (provided by the
laboratory), and then into the ice chest with ice surrounding the bottles. (Note: only
ultra -clean polypropylene or HPDE material sealed bags are allowed).
• Place the COC seal across the top of each sample bottle cap.
• Sample personnel will collect appropriate quality control samples (field blank, trip blanks
and split samples). One field sample per sample site, one trip blank per ice chest.
• A two -person sample team is recommended: One team member obtains the samples,
and other records the. samples in the COC form with the sample collection information.
• Record field site observations in the field notebook' (such as types of pipes and fittings,
time well operated prior to sample, site characteristics, atmospheric conditions, etc.).
Take pictures documenting the specific conditions encountered and how the sample was
collected. Record this information at the time of sampling.
AFTER SAMPLING
All team members coming out of the site sampling area must immediately conduct personal
decontamination.
• Remove your gloves and place them in a sealable plastic bag.
• Wash your hands with Alconox ® soap and rinse with deionized water.
' The field notebook should not be waterproof
19E-25
PFAS Sampling Guidance
SAMPLE SHIPPING
• Samples should be stored in ice chests at least 1/3 filled with wet ice and do not exceed
100C (50°F) until analyzed at the laboratory. If the immediate analysis is not possible,
samples should be stored at 10°C (50°F) while independently enclosed to their individual
sealed bag provided until extraction but must not be frozen or stored in blue ice/chemical
ice.
o Samples must arrive at the laboratory within 48 hours of sampling, and at a
temperature between 10°C (50°F) and 0°C (32°F) but not frozen.
o If samples are received at the laboratory more than 48 hours after sampling they must
be between 6°C (42.8°F) and 0°C (32°F) but not frozen.
• Pack the bottles (which are placed inside sealable plastic bags provided by the laboratory)
upright in the ice chest. Ensure that the bottles cannot move sideways at all. Any extra
space should be packed with ice.
• Put additional Ice inside of double plastic bags and place these on top of the bottles.
The COC form will accompany all samples and be filled out at the same time samples are
collected.z The COC form is an integral part of sample QA/QC, each ice chest should
include a COC.
o Ensure that the COC is complete and ready to be signed by lab representative, carrier
or overnight service, and retain the sender's copy.
o Place the COC in a sealed plastic bag (1 gallon) inside of the cooler.
• Seal the ice chest firmly by wrapping tape around it multiple times. Put labels stating "keep
chilled" on the outside of the ice chest.
• Attach plastic overnight carrier tags to the ice chest's handle, retain the marked sender's
copy for the record tracking number.
• Provide the shipping information to the laboratory and communicate the potential time of
arrival of the samples.
2 The general Information from the COC could be filled ahead (Contact Information, samplers name)
19E-26
PFAS Sampling Guidance
ATTACHM ENT A
Recommended Materials and Supplies Checklist:
❑ Sampling procedure document (Methods for sampling)
❑ Site location Information
❑ Chain of custody forms
❑ Extra sample labels for each sample
❑ Sample bottles
❑ Number of sites to be sampled:
❑ Number of sample bottles:
❑ Number of Field Blanks:
❑ Number of Trip Blanks:
❑ TrizmaO (preservative, unless added to the bottles by the laboratory)
❑ Cooler (ice chest) and ice
❑ Packing material if samples are to be shipped
❑ Field notebook, but not waterproof paper
❑ Office supplies (pens, tape)
❑ Powderless nitrile gloves
❑ Paper towels
❑ Scissors/cutter
❑ Deionized water (DI)
❑ Resealable bags [(jumbo (2.5 gal); large (1 gal); and medium (1 quarter)] ultra -clear
Polypropylene or HPDE material (only).
❑ Alconox ® soap
❑ Folding table
❑ Field clipboard
❑ Overnight carrier shipping forms
0 Temperature/pH/EC meter
❑ Safety glasses
❑ Camera and charger— ensure time and date stamps are on digital camera image
7
19E-27
19E-28
EPA's PFAS Action Plan outlines concrete steps
the agency is taking to address PFAS and to
protect public health.,
EPA's Per- and Polyfluoroalkyl Substances (PFAS).
Action Plan:
• Demonstrates the agency's critical national leadership,. I
by providing both short-term solutions and long-term
strategies to address this important issue.
• Provides a multi -media, multi -program, national research and risk
communication plan to address this emerging environmental challenge.
• Responds to the extensive public input the agency has received over the past year during the PFAS National
Leadership Summit, multiple community engagements, and through the public docket.
EPA is taking a proactive, cross -agency approach to addressing PFAS. The key actions EPA is taking to help provide
the necessary tools to assist states, tribes, and communities in addressing PFAS are summarized below.
I
T
EPA is moving forward with the Maximum
Contaminant Level (MCL) process for PFOA and
PFOS—two of the most well-known and prevalent
HAS chemicals. The Agency is also gathering and
evaluating Information to determine If regulation is
appropriate for a broader class of PFAS.
The next step in the Safe Drinking WaterAct process
for issuing drinking water standards is to propose a
regulatory determination. This provides the opportunity
for the public to contribute to the information the
EPA will consider related to the regulation of PFAS in
drinking water.
EPA continues strengthening enforcement authorities
and clarifying cleanup strategies through actions
such as designating PFOA and PFOS as hazardous
substances and developing interim groundwater
cleanup recommendations.
This important work will provide additional tools to help
states and communities address existing contamination
and enhance the ability to hold responsible parties
accountable.
EPA is considering the addition of PFAS chemicals to
the Toxics Release Inventory and rules to prohibit the
uses of certain PFAS chemicals.
The Toxics Release Inventory would make information
about certain PFAS releases reported by certain
industrial sectors and federal facilities available.
Additionally, the TSCA new chemicals program will help
manage and, as necessary, reduce risk to human health
and the environment from new PFAS.
')NITOF
EPA will propose nationwide drinking water monitoring
for PFAS under the next UCMR monitoring cycle.
Monitoring results will improve understanding of the
frequency and concentration of PFAS occurrence in drinking
water, which can be used to inform regulatory action.
EPA is rapidly expanding the scientific foundation for
understanding and managing risk from PFAS.
Improved detection and measurement methods,
additional information about PFAS presence in the
environment and drinking water, better understanding of
effective treatment and remediation methods, and more
information about the potential toxicity of a broader set
of PFAS will help EPA, states, and others better manage
PFAS risks.
EPA uses enforcement tools, when appropriate, to
address PFAS exposure in the environment and assist
states in enforcement activities.
EPA seeks to support communities that have PFAS
releases by using federal enforcement authorities, where
appropriate.
1MMONICATIC
EPA will work collaboratively to develop a risk
communication toolbox that Includes multi -media
materials and messaging for federal, state, tribal, and
local partners to use with the public.
This will help ensure clear and consistent messages to the
public and will help address concerns related to PFAS.
EXHIISE-29
19E-30
State Water Board Releases Guidelines for
Testing and Reporting on PFOA and PFOS in Drinking Water
Division of Drinking Water Provides Guidance to Water Systems Statewide
For Release:
July 13, 2018
Contact: George Kostyrko
george. kostyrko (a_)waterboards.ca.gov
SACRAMENTO — The State Water Resources Control Board today established new drinking
water guidelines for local water agencies to follow in detecting and reporting the presence of
contaminants once used in grease and stain -resistant coatings for consumer products and
firefighting foams.
The guidelines adopted by the board's Division of Drinking Water (DDW) set interim
Notification Levels of 14 parts per trillion (ppt) for perfiuorooctanoic acid (PFOA) and 13 ppt for
perfluorooctanesulfonic acid (PFOS), chemicals that were widely used in consumer products
until they were phased out in the 2000s due to health concerns. Exposure to PFOA and PFOS
over certain levels is associated with adverse health effects that include cancer and
developmental harm.
The new guidelines are based on the most health protective levels set by other states and
follow a recommendation by the California Environmental Protection Agency's Office of
Environmental Health Hazard Assessment. The notification levels are being adopted on an
interim basis while OEHHA conducts further analysis and develops a final recommendation
later this year.
The notification guidelines do not require water agencies to test their water for these
contaminants, although most California water systems serving more than 10,000 people
already have. But if they do test and the level is exceeded, then water agencies are required to
report the results to their governing boards and to the State Water Board. They are also urged
to report this information to their customers.
The establishment of a notification level is often an initial step in the process of adopting a
formal state regulatory standard, called a Maximum Contaminant Level. Data collected as a
result of the new guidelines, reflecting the extent and levels of contamination, will inform
DDW's decision about whether to adopt a regulatory standard for PFOA and PFOS.
As part of these guidelines, DDW is also establishing an interim Response Level of 70 ppt for
the total combined concentration of PFOA and PFOS, consistent with the U.S. Environmental
Protection Agency's health advisory level established in 2016. If this level is exceeded in
STATE WATER RESOURCES CONTROL BOARD
1001 I Street, Sacramento, CA 95816 • Malting Address: P.O. Box 100, Sacramento, CA 9 5 812-010 0 • www.waterboards.ca.9ov
Exx"V 31
drinking water provided to consumers, DDW recommends that the water agency remove the
water source from service.
In California 455 public water systems have tested for PFOA and PFOS. Of those, eight
systems reported exceedances of the 70 ppt level for either PFOA, PFOS or both combined.
These systems either have taken steps to treat their water to a level below the health advisory
or have taken the water source out of service.
Part of a family of chemicals known as perfluoroalkyl substances, PFOA and PFOS were
routinely used in grease -proof coatings for food packaging; stain -resistant coatings for carpets,
clothing and furniture; and as an ingredient in coatings for not -stick cookware. In addition,
these compounds have also been used in fire -retarding foams and various industrial
processes.
While consumer products are a large source of exposure to these chemicals for most people,
drinking water has become an increasing concern due to their persistence in the environment
and tendency to accumulate in groundwater. Groundwater contamination is typically localized
and associated with an industrial facility where these chemicals were manufactured or used in
other products, or airfields which used the chemicals for firefighting.
For more information on the work the State Water Board's Division of Drinking Water is doing
in tracking voluntary monitoring and reporting by public water systems with these two
compounds, please visit a resource page found here.
M.
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