Understanding the Latest PADEP Guidelines for Public Water Suppliers on Federal PFAS Regulation

The Pennsylvania Department of Environmental Protection (PADEP) has issued an important update via email for public water suppliers concerning the federal PFAS National Primary Drinking Water Regulation (NPDWR), published by the EPA on April 26, 2024. At Suburban Testing Labs, we strive to be your guide to help you through it all.  Here’s a breakdown of what you need to know:

Key Points:

• Current Compliance: The federal PFAS NPDWR is not yet in effect, but Pennsylvania’s PFAS Maximum Contaminant Level (MCL) Rule remains active. Water systems must continue to adhere to the state’s MCLs of 14 ppt for PFOA and 18 ppt for PFOS, along with all other state regulations.
• State and Federal Integration: PADEP is reviewing the federal rule and will develop state regulations that incorporate any stricter federal provisions. Training on new requirements will be provided before the publication of Pennsylvania’s revised rule.
• EPA-Approved Methods: Only two methods are approved for PFAS analysis—EPA 533 and EPA 537.1 version 2.0. Ensure your accredited lab meets the federal practical quantitation limits (PQLs), which are lower than Pennsylvania’s minimum reporting levels (MRLs).  Suburban Testing Labs is currently using EPA 533 to meet the Federal Rule, and expects to have 537.1 Rev. 2.0 in the near future.  We are currently accredited for 537.1 Rev. 1.0.

Monitoring Requirements:

• Trigger Levels: The federal rule includes Trigger Levels for each regulated PFAS, which are used to determine compliance monitoring frequency starting April 26, 2027.
  • PFOA and PFOS: 2.0 ppt
  • PFNA, PFHxS, HFPO-DA (Gen X): 5.0 ppt
• PFAS Contaminants: The federal rule sets MCLs for six PFAS: PFOA, PFOS, PFHxS, PFNA, HFPO-DA (GenX), and PFBS.
• Initial Monitoring Data: Data collected on or after January 1, 2019, may be used for compliance with initial federal monitoring if it meets specified criteria.

What This Means for PA Water Systems:

1. Ongoing State Compliance: Continue quarterly monitoring as required by Pennsylvania’s PFAS MCL Rule.
2. Federal Monitoring Preparation: You can start monitoring that meets both state and initial federal requirements. Ensure samples are collected as per both regulations:

• • Groundwater systems serving >10,000 people and all surface water systems: 4 quarterly samples spaced 2-4 months apart.
  • Groundwater systems serving ≤10,000 people: 2 samples spaced 5-7 months apart.

Action Items for 2024 and 2025:

• For PWSs Conducting Initial Monitoring in 2024:
  • Space quarterly samples to meet both state and federal requirements.
  • Request lab analysis for the six PFAS using methods 533 or 537.1 version 2.0.  Suburban Testing Labs is currently using EPA 533.
  • Ensure all results are reportable to PA DEP, including reporting limits and trigger levels.
•  For PWSs Serving ≤350 Customers in 2025:
  • Follow similar steps to ensure compliance with both state and federal initial monitoring requirements.

For detailed comparison tables and more information, visit PA DEP’s and EPA’s websites.  Suburban Testing Labs is equipped to perform your PFAS analysis, meeting both PADEP and USEPA testing requirements.  PLUS, no need to have your samples shipped to an out of state lab.  We handle all analysis at our Reading, PA headquarters.

Need testing for your wastewater treatment plant, groundwater, or leachate?  We are also accredited to perform PFAS analysis via finalized EPA Method 1633.  Contact us for information for all your PFAS testing needs.

If you have questions, reach out to PA DEP Bureau of Safe Drinking Water at RA-EPSDWTECHSUPPORT@pa.gov.

By staying informed and proactive, you can effectively manage PFAS monitoring and compliance, ensuring safe drinking water for your community.

Our Commitment to Excellence

At Suburban Testing Labs, our mission is to provide high-quality analytical services that safeguard public health and the environment. Achieving PFAS accreditation demonstrates our dedication to maintaining the highest standards of accuracy and reliability in our testing processes.  We are committed to supporting our clients with the best testing services available, helping them navigate complex regulatory requirements and make informed decisions.

Contact Us

For more information about our PFAS testing services or to discuss your specific testing needs, please visit our website or contact us at info@suburbantestinglabs.com.

About Suburban Testing Labs

Suburban Testing Labs is a leading environmental testing laboratory dedicated to providing high-quality analytical services. With a focus on accuracy, reliability, and customer satisfaction, we serve a diverse range of clients across various industries.

Contact Information:

Suburban Testing Labs
Phone: (610) 375-8378
Email: info@suburbantestinglabs.com