PFAS: EPA will require all public water systems to sample 29 analytes starting in 2023

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Public water system operators in Wisconsin will soon be required to evaluate their systems for the presence of the two most studied PFAS analytes – perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) – under the state law. Additionally, municipalities in Wisconsin receive mandatory guidelines from the US government to assess a broader list of per- and polyfluoroalkyl substances (PFAS) in drinking water.

On December 27, 2021, the U.S. Environmental Protection Agency (EPA) released the fifth Unregulated Contaminant Monitoring Rule (UCMR 5) which requires all public water systems serving more than 10,000 people to sample and analyze the presence of 29 PFAS and the heavy metal, lithium, in a determined interval between 2023 and 2025. The sampling program must take place over a period of 12 months. Most systems will need to share a set of four quarterly samples with the EPA. Sampling results will be subject to Wisconsin public records laws and compiled by the EPA for summary in a report to be released in 2026.

Greater range

The UCMR test is a requirement of the Clean Drinking Water Act. Previous UCMR testing that included some PFAS was conducted from 2013 to 2015 as part of UCMR 3. Unlike UCMR 3, which required systems serving more than 10,000 people to sample six PFAS analytes, UCMR 5 applies to all public water systems serving more than 3,300 people. . This effort will also include a nationally representative sampling of systems serving less than 3,300 people. Another expansion in UCMR 5 is the inclusion of 29 PFAS and at much lower reporting limits than previously applied in UCMR 3.

As Wisconsin law will soon require the limited assessment of PFOA and PFOS and compliance with the current EPA lifetime health advisory limit set in 2016 at 70 parts per trillion, the question of which communities drink PFAS in Wisconsin will be answered definitively by UCMR 5.

Advances in Testing Methodology

UCMR 5 specifically requires the use of the newer EPA drinking water method, 533 for 25 PFAS, as well as the older EPA method that was used during UCMR 3. method 537.1 is required for the remaining four PFAS that are not captured by 533. Minimum reporting levels (MRLs) are set at 2-5 ppt for most compounds, with the highest limit at 20 ppt. This contrasts with UCMR 3 with MRLs of 10-90 ppt for the six PFASs. The EPA oversees the laboratory approval program for UCMR testing. In January 2022, the EPA published a list of thirteen laboratories approved to support Methods 533 and 537.1. This list may grow as laboratories can request authorization to participate in UCMR 5 until August 1, 2022.

Sampling frequency

The drinking water source controls the sampling frequency for the required 12-month assessment. For public water systems that obtain drinking water primarily from surface water sources, four sampling events should occur, three months apart, over a period of one year. For public drinking water systems that derive their drinking water from groundwater, sampling should occur twice within a one-year period (two sampling events in total, separated by five to seven months).

Potential schedule flexibility

The UCMR 5 cycle begins in January 2022 and ends in December 2026. The rule specifies that sample collection can begin as early as January 1, 2023 and must end no later than December 31, 2025. 10,000 are eligible to change this schedule.

EPA takes leadership role

While the 29 PFASs selected for UCMR 5 are currently on the Wisconsin Department of Natural Resources (DNR) list of 33 PFAS analytes, the DNR, including its policy-making Natural Resources Board (NRB), has no active role in administering UCMR 5 requirements or compliance. Public water systems are responsible for reporting results directly to the EPA.

Receding groundwater is delaying the inevitable

While the first attempt to enact a groundwater rule based on the Department of Health Services (DHS) recommended standards for PFOA and PFOS failed to pass the NRB, the DNR remains legally obligated to enact rules for contaminants based on public health recommendations from DHS in Wis. Statistics Chapter 160. On June 23, 2021, NRB approved two scope statements for additional PFAS rules. For PFOA and PFOS, MNR can choose to either repeat the process for all Cycle 10 contaminants or revise its 2021 scoping statements to add PFOA and PFOS using the Wis-based process. Stat. subsection 227.135(4). Both options have drawbacks.

The 12 PFAS analytes included in the respective new groundwater and drinking water rules are each included in the EPA’s UCMR 5 list. MNR must promulgate these rules by June 2024 or the scope statement will expire.


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