The Environmental Protection Agency (EPA) requires water utilities to test drinking water for per- and polyfluoroalkyl substances (PFAS). Utilities have the option to conduct the testing in-house or hire an external laboratory.
To help the utilities decide which method is best for them, the American Water Works Association (AWWA) held a webinar last month to discuss the advantages and disadvantages of internal or external PFAS testing.
The professionals providing information on PFAS testing included Jeff Smith, the director of operations at Complete Environmental Testing (CET) where he has been building the PFAS department, and Alan D. Martin, a public health scientist with the North Carolina Department of Environmental Quality where he oversees PFAS analytics, testing and method development in the waters.
The webinar discussion opened with Smith saying the costs associated with testing are among the most critical factors public-water utilities need to consider when deciding to test water for PFAS in house, or to contract a laboratory to conduct those tests.
The need to test water for PFAS substances is related to the EPA final rule issued on April 10, 2024 that sets drinking water standards for five individual PFAS substances, including PFOA, PFOS, PFNA, PFHxS, and HFPO-DA. In addition, on April 19, 2024 EPA issued a second PFAS rule designating the PFAS substances perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as hazardous substances because those chemicals have been linked to cancers, immune and developmental damage to infants and children, and has some impact on the liver and heart.
“It’s very expensive to bring PFAS in house,” said Smith, who listed the “upfront costs” a utility will face for “bringing it (PFAS testing) on board.” Those costs include:
- Training personnel to collect, analyze, and understand the type of samples that are collected.
- Creating a clean-space laboratory that is purged of contamination.
- Obtaining PFAS-free consumables, such as solvents or any lab consumables.
In addition, the volume of water samples a water utility will test for PFAS, and how often—semiannually or quarterly—are leading factors that will influence if a water utility conducts the testing, or contracts a laboratory to test the samples, according to Smith. Those are some of the things that water utilities want to look at before making a decision to go into PFAS testing or contract it out to a commercial lab, he said.
Martin agrees saying “how many samples are you (a water utility) going to run” will decide if the utility will do in-house testing, or contract out. If the number of samples is “really low volume and you can afford to pay (a contractor) $400 or $500 a sample, it’s not a big deal,” he said.
However, those water utilities that do decide to conduct in-house testing need to know that “the initial investment” will be about $500,000 to establish a clean room; to hire people and cover salaries; and for the consumables, Martin said. “Do the math, if you're only doing 10 samples a month, it probably doesn’t make sense,” he said.
However, if a water utility decides to contract a laboratory to test water samples for PFAS, the contractor needs to be both “capable and accredited with all the EPA methods,” said Martin, who added the contractor needs to be a reliable communicator with the utility companies, and with other laboratories, especially when there are challenges.
“It’s all communication,” Martin said. “We’re communicating with the samplers. We're training the samplers, providing as much training as they need because if samples come in the back door wrong, then we lose a few days trying to straighten things out,” he added.
Therefore, having relationships with other facilities “is really critical,” said Martin, who cited a situation he experienced in which chemical “issues with the data” tainted the samples. “We found weird things taking place analytically with those (samples), I didn’t have the bandwidth to attack that, so we reached out to our commercial partners and said, ‘Hey, we’re seeing these issues with the data, can you address that?’” and despite being short notice, they were “able to help us with that,” he said.
In that situation, the commercial partner was able to “tweak the methods,” and while the situation was “not true academic research and development,” having a partner “that can go outside of just normal EPA methods, I think is really critical,” Martin said.
Communication between the utility companies and the commercial labs “is spot on,” because such communication can help “in establishing methods,” or “discussing how we might analyze something or approach a short chain or a novel compound,” said Smith. Furthermore, such communications can keep water sector officials informed enough to prepare for “what’s coming next,” said Smith, who added officials can learn where to access resources to deal with future challenges.
The EPA’s webpage lists good resources that can help water utilities prepare for “what’s coming next,” Smith said. Among the latest EPA resource is the Tackling Emerging Contaminants (TEC) initiative, which is a no-cost technical assistance program designed to reduce exposure to PFAS and other emerging contaminants in small or disadvantaged communities. Announced on Nov. 20, 2024, the EPA says TEC is tasked with providing technical water assistance to help eligible public drinking-water systems conduct initial water quality testing, evaluate emerging contaminant issues, and identify next steps in 200 small or disadvantaged communities over the next three years at no cost to the communities.
In addition, there are states that offer “great resources,” Smith said. Among those are Connecticut, which provides water-related resources for the public health and engineering sectors, Smith said.
Michigan provides “great information,” including “a whole guideline of sampling do’s, and don’ts,” Smith said.
The Interstate Technology and Regulatory Council—a national coalition focused on developing tools and strategies to reduce barriers to deploying innovative environmental technologies—“is a great resource” for PFAS tools, Smith said.
There are also work groups, according to Smith. “There's a ton of work groups. If you want to put in the effort to find a work group that’s handling PFAS, you can do that.
Lastly, any environmental or analytical conference will probably have “a huge segment” of presentations on PFAS.
“So the information’s out there, and it’s attainable,” Smith said.