Since EPA has not finalized their methodology for measuring PFAS in non-drinking water, the Department of Defense has defined a methodology to analyze PFAS to meet requirements under CERCLA, CWA, and RCRA.
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When it comes to drinking water, EPA specifically requires sampling methods and lays out defined Maximum Contaminant Limits (MCLs). However when it comes to non-potable water, the rules are a bit murky. EPA outlines method 537.1 for non-potable water, and there are set limits for when an operator is required to respond and mitigate, but there is no set MCL (yet).
SW-846 Method 8327 is a validated method for measuring 24 PFAS in groundwater, surface water, and wastewater samples , but it does not meet requirements needed for decision making. EPA issued Draft Method 1633 in August 2021 to analyze 40 PFAS constituents using isotope dilution methods for non-potable water and solids. This is considered to be the foundation for future wastewater and stormwater discharge monitoring that EPA hopes to enact in 2022.
Since EPA has not yet finalized their methodology for measuring PFAS in non-drinking water, the Department of Defense (DoD) has set out a methodology to sample and analyze 40 PFAS in environmental media (water, soil, air) to meet requirements under CERCLA, CWA, and RCRA. It is outlined in the DoD's Quality Systems Manual (QSM) for Environmental Laboratories, version 5.4, in Table B-24.
Because the DoD document was written for meeting requirements under CWA, it is appropriate for operators submitting a Stormwater Pollution Prevention Plan as part of their application for a Multi-Sector General Permit (MSGP) for stormwater runoff at industrial sites.
If you are unclear on which method to use, laboratories these days have dedicated PFAS experts that can guide you:
I have personally interacted with the labs listed above and can attest that they all have great response times. (I was not paid for these endorsements.)
- Download EPA Method 533 for PFAS in drinking water using isotope dilution and liquid chromatography/tandem mass spectrometry.
- Download EPA Method 537.1 for 18 PFAS in drinking water using solid phase extraction and liquid chromatography/tandem mass spectrometry.
- EPA is conducting ongoing research on PFAS.
- Read EPA's tips for reviewing LC/MS/MS data generated from PFAS analytical methods.
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