(August 28, 2019) - NACWA submitted comments August 23 to EPA on a proposed new analytical procedure for validating 24 per- and polyfluoroalkyl substances (PFAS) using liquid chromatography/tandem mass spectrometry analysis.
The comments respond to an EPA request for public comment that was issued in June. NACWA requested, and received, a 30-day extension of the comment period.
The methodology at issue, Method 8327, is traditionally used to evaluate solid waste, but it can be used to help evaluate PFAS chemicals in groundwater, surface water, and wastewater.
NACWA’s comments highlighted a number of concerns with this new methodology, including that nearly half the analytes tested revealed significant issues with reproducibility, response, recovery, stability, and chromatography. New, advanced analytical capabilities to measure PFAS down to the part per trillion level exposes concerns as to whether laboratories can obtain representative samples that are truly reflective of the population studied.
NACWA stressed that until it is possible to verify that sampling equipment, laboratory staff and/or the personnel conducting the sampling are not contaminating samples, EPA must not move forward until there is sufficient scientific confidence to resolve the problems found in the validation study.
NACWA also emphasized that as the understanding of PFAS continues to mature and evolve, it is imperative that any methodologies used to quantify PFAS be precise and reproduceable. Since public wastewater utilities are not sources of PFAS but rather passive receivers, the cost placed on utility ratepayers for sampling and analysis or any potential regulatory compliance requirements cannot be based on inconsistent, deficient, or unverifiable data.
NACWA would like to thank member utility the Sanitation Districts of Los Angeles County for their thoughtful comments and assistance to understand the chemistry behind this methodology.
If members have questions regarding NACWA’s comments or EPA’s draft methodology, please contact Emily Remmel, NACWA’s Director of Regulatory Affairs.