Practical Overview of PFAS National Drinking Water Regulation

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Explore the key aspects of the PFAS National Primary Drinking Water Regulation, including MCLs, rounding requirements, Hazard Index, PQLs, rule deadlines, and reporting guidelines. Learn about practical information on compound levels, hazard assessment, monitoring procedures, and compliance deadlines.

  • PFAS
  • Drinking Water
  • Regulation
  • Hazard Index
  • Compliance
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  1. PFAS - National Primary Drinking Water Regulation (NPDWR) Presented By: Sierra Bettis Guam Environmental Protection Agency

  2. Topics Final Maximum Contaminant Levels (MCLs) Rounding Requirements Hazard Index (HI) Practical Quantitative Levels (PQLs) Rule Deadlines Reporting

  3. Rule Overview PRACTICAL QUANTITATION LEVELS FINAL MCLG FINAL MCL TRIGGER LEVEL COMPOUND PFOA 0 4.0 ppt 2.0 ppt 4.0 ppt PFOS 0 4.0 ppt 2.0 ppt 4.0 ppt PFHxS 10 ppt 10 ppt 5 ppt 3.0 ppt PFNA 10 ppt 10 ppt 5 ppt 4.0 ppt HFPO-DA (GenX) 10 ppt 10 ppt 5 ppt 5.0 ppt Mixture of 2 or more: PFHxS, PFNA, HFPO- DA, and PFBS (Hazard Index) 1 1 0.5 N/A (unitless) (unitless) (unitless)

  4. Rounding Calculation of the running annual average (RAA) PFOS and PFOA have 2 significant figures PFHxS, PFNA, GenX, and the Hazard Index (HI) have 1 significant figure Rounding occurs after the RAA

  5. Hazard Index Hazard Index (HI) - mixture of 2 or more chemicals Hazard Quotient (HQ) / Health Based Water Concentration (HBWC) HQ = ratio of measured concentration in drinking water to the HBWC HBWC = the level below where there are no known adverse health effects over time of exposure and allows for margins of safety If the HI > than 1 (unitless) = exceedance of the MCL HI Equation: ((HFPO-DA/10 ppt) + (PFBS/2000 ppt) + (PFNA/10 ppt) + (PFHxS/10 ppt))

  6. Practical Quantitation Levels (PQLs) COMPOUND FINAL MCL PQLs Sample results below the PQL will be 0 for MCL compliance Sample results below the PQL be used to determine Trigger Levels PFOA 4.0 ppt 4.0 ppt PFOS 4.0 ppt 4.0 ppt PFHxS 10 ppt 3.0 ppt PFNA 10 ppt 4.0 ppt HFPO-DA (GenX) 10 ppt 5.0 ppt Hazard Index 1 (unitless) N/A

  7. Rule Deadlines Initial Monitoring - Completed by April 26, 2027 Surface water systems Quarterly monitoring within a 12-month period Groundwater systems greater than 10,000 customers Quarterly monitoring within a 12-month period Groundwater systems serving less than 10,000 customers Monitor twice within a 12-month period PWSs must include results of their PFAS initial monitoring into their CCRs PWSs must start issuing public notification for any monitoring and testing procedure violations

  8. Rule Deadlines Compliance Monitoring - Beginning on April 26th, 2029 PWSs must comply with all regulated PFAS MCLs PWSs must provide notification to the public of results Based on results from initial monitoring: Quarterly monitoring - greater than the trigger level for all regulated PFAS Annual monitoring - below the trigger level for all regulated PFAS Triennial monitoring - below the trigger level for all regulated PFAS for 3 consecutive years of annual monitoring Triennial monitoring - below the trigger level for an entry point for all regulated PFAS

  9. Reporting Tier 2 Public Notice (PN) - MCL/MRDL/TT Violation Delivered within 30 days after learning of the violation Systems will be required to provide Tier 2 notifications starting in 2029 Tier 3 Public Notice (PN) - Monitoring and Testing Procedure Violation Delivered within 1 year after learning of the violation Systems will be required to provide Tier 3 notifications starting in 2027

  10. Calculation Examples - PFOS MCL EX 1: 1ST QUARTER PFOS = 6.2 ppt; 2ND QUARTER PFOS = 2.1 ppt ; 3RD QUARTER PFOS = 3.5 ppt ; 4TH QUARTER PFOS = 5.1 ppt

  11. Calculation Examples - PFOS MCL EX 1: 1ST QUARTER PFOS = 6.2 ppt; 2ND QUARTER PFOS = 2.1 ppt ; 3RD QUARTER PFOS = 3.5 ppt ; 4TH QUARTER PFOS = 5.1 ppt RAA: 6.2 + 0 + 0 + 5.1 = 11.3/4 = 2.825 ppt

  12. Calculation Examples - PFOS MCL EX 1: 1ST QUARTER PFOS = 6.2 ppt; 2ND QUARTER PFOS = 2.1 ppt ; 3RD QUARTER PFOS = 3.5 ppt ; 4TH QUARTER PFOS = 5.1 ppt RAA: 6.2 + 0 + 0 + 5.1 = 11.3/4 = 2.825 ppt Rounded to: 2.8 ppt NO MCL EXCEEDANCE

  13. Calculation Examples - PFOS MCL EX 1: 1ST QUARTER PFOS = 6.2 ppt; 2ND QUARTER PFOS = 2.1 ppt ; 3RD QUARTER PFOS = 3.5 ppt ; 4TH QUARTER PFOS = 5.1 ppt RAA: 6.2 + 0 + 0 + 5.1 = 11.3/4 = 2.825 ppt Rounded to: 2.8 ppt NO MCL EXCEEDANCE but EXCEEDS THE TRIGGER LEVEL OF 2.0 ppt because of the quarter 1 and quarter 3 sample results

  14. Calculation Examples - Hazard Index (HI) EX 2: 1ST QUARTER PFHxS = 11.0 ppt, PFNA = 10.2 ppt; 2ND QUARTER PFHxS = 9.2 ppt, PFNA = 11.7 ppt; 3RD QUARTER PFHxS = 9.5 ppt, PFNA = 8.2 ppt; 4TH QUARTER PFHxS = 8.3 ppt, PFNA = 9.1 ppt

  15. Calculation Examples - Hazard Index (HI) EX 2: 1ST QUARTER PFHxS = 11.0 ppt, PFNA = 10.2 ppt; 2ND QUARTER PFHxS = 9.2 ppt, PFNA = 11.7 ppt; 3RD QUARTER PFHxS = 9.5 ppt, PFNA = 8.2 ppt; 4TH QUARTER PFHxS = 8.3 ppt, PFNA = 9.1 ppt ((HFPO-DA/10 ppt) + (PFBS/2000 ppt) + (PFNA/10 ppt) + (PFHxS/10 ppt))

  16. Calculation Examples - Hazard Index (HI) EX 2: 1ST QUARTER PFHxS = 11.0 ppt, PFNA = 10.2 ppt; 2ND QUARTER PFHxS = 9.2 ppt, PFNA = 11.7 ppt; 3RD QUARTER PFHxS = 9.5 ppt, PFNA = 8.2 ppt; 4TH QUARTER PFHxS = 8.3 ppt, PFNA = 9.1 ppt ((HFPO-DA/10 ppt) + (PFBS/2000 ppt) + (PFNA/10 ppt) + (PFHxS/10 ppt)) Quarter 1: 0 + 0 + (10.2 ppt /10 ppt) + (11.0 ppt /10 ppt) = 1.02 + 1.10 = 1.12

  17. Calculation Examples - Hazard Index (HI) EX 2: 1ST QUARTER PFHxS = 11.0 ppt, PFNA = 10.2 ppt; 2ND QUARTER PFHxS = 9.2 ppt, PFNA = 11.7 ppt; 3RD QUARTER PFHxS = 9.5 ppt, PFNA = 8.2 ppt; 4TH QUARTER PFHxS = 8.3 ppt, PFNA = 9.1 ppt ((HFPO-DA/10 ppt) + (PFBS/2000 ppt) + (PFNA/10 ppt) + (PFHxS/10 ppt)) Quarter 1: 0 + 0 + (10.2 ppt /10 ppt) + (11.0 ppt /10 ppt) = 1.02 + 1.10 = 1.12 RAA for HI: 1.12 + 2.09 + 1.77 + 1.74 = 6.72/4 = 1.68

  18. Calculation Examples - Hazard Index (HI) EX 2: 1ST QUARTER PFHxS = 11.0 ppt, PFNA = 10.2 ppt; 2ND QUARTER PFHxS = 9.2 ppt, PFNA = 11.7 ppt; 3RD QUARTER PFHxS = 9.5 ppt, PFNA = 8.2 ppt; 4TH QUARTER PFHxS = 8.3 ppt, PFNA = 9.1 ppt ((HFPO-DA/10 ppt) + (PFBS/2000 ppt) + (PFNA/10 ppt) + (PFHxS/10 ppt)) Quarter 1: 0 + 0 + (10.2 ppt /10 ppt) + (11.0 ppt /10 ppt) = 1.02 + 1.10 = 1.12 RAA for HI: 1.12 + 2.09 + 1.77 + 1.74 = 6.72/4 = 1.68 Rounded to: 2 MCL EXCEEDANCE OF THE HI

  19. Calculation Examples ARE WE DONE?

  20. Calculation Examples - PFHxS MCL (EX2 Continued) EX 2: 1ST QUARTER PFHxS = 11.0 ppt, PFNA = 10.2 ppt; 2ND QUARTER PFHxS = 9.2 ppt, PFNA = 11.7 ppt; 3RD QUARTER PFHxS = 9.5 ppt, PFNA = 8.2 ppt; 4TH QUARTER PFHxS = 8.3 ppt, PFNA = 9.1 ppt

  21. Calculation Examples - PFHxS MCL (EX2 Continued) EX 2: 1ST QUARTER PFHxS = 11.0 ppt, PFNA = 10.2 ppt; 2ND QUARTER PFHxS = 9.2 ppt, PFNA = 11.7 ppt; 3RD QUARTER PFHxS = 9.5 ppt, PFNA = 8.2 ppt; 4TH QUARTER PFHxS = 8.3 ppt, PFNA = 9.1 ppt RAA for PFHxS: 11.0 + 9.2 + 9.5 + 8.3 = 38/4 = 9.5 ppt

  22. Calculation Examples - PFHxS MCL (EX2 Continued) EX 2: 1ST QUARTER PFHxS = 11.0 ppt, PFNA = 10.2 ppt; 2ND QUARTER PFHxS = 9.2 ppt, PFNA = 11.7 ppt; 3RD QUARTER PFHxS = 9.5 ppt, PFNA = 8.2 ppt; 4TH QUARTER PFHxS = 8.3 ppt, PFNA = 9.1 ppt RAA for PFHxS: 11.0 + 9.2 + 9.5 + 8.3 = 38/4 = 9.5 ppt Rounded to one significant figure = 10 ppt NO MCL EXCEEDANCE OF PFHxS

  23. Calculation Examples - PFHxS MCL (EX2 Continued) EX 2: 1ST QUARTER PFHxS = 11.0 ppt, PFNA = 10.2 ppt; 2ND QUARTER PFHxS = 9.2 ppt, PFNA = 11.7 ppt; 3RD QUARTER PFHxS = 9.5 ppt, PFNA = 8.2 ppt; 4TH QUARTER PFHxS = 8.3 ppt, PFNA = 9.1 ppt RAA for PFHxS: 11.0 + 9.2 + 9.5 + 8.3 = 38/4 = 9.5 ppt Rounded to one significant figure = 10 ppt NO MCL EXCEEDANCE OF PFHxS but EXCEEDS THE TRIGGER LEVEL OF 5.0 ppt

  24. Calculation Examples ARE WE DONE?

  25. Calculation Examples - PFNA MCL (EX2 Continued) EX 2: 1ST QUARTER PFHxS = 11.0 ppt, PFNA = 10.2 ppt; 2ND QUARTER PFHxS = 9.2 ppt, PFNA = 11.7 ppt; 3RD QUARTER PFHxS = 9.5 ppt, PFNA = 8.2 ppt; 4TH QUARTER PFHxS = 8.3 ppt, PFNA = 9.1 ppt RAA for PFNA: 10.2 +11.7 + 8.2 + 9.1 = 39.2/4 = 9.8 ppt Rounded to one significant figure = 10 ppt NO MCL EXCEEDANCE OF PFHxS but EXCEEDS THE TRIGGER LEVEL OF 5.0 ppt

  26. Questions? Email: sierra.bettis@epa.guam.gov Phone number: 671-300-4776

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