Connecticut Department of Energy & Environmental Protection

PFAS Information for Environmental Professionals

Remediation Roundtable PFAS Updates
PFAS Sampling Guidance
PFAS Analytical Methods
PFAS Remediation Criteria
CTDPH Drinking Water Action Levels for PFAS
PFAS Release Reporting
Significant Environmental Hazards and PFAS
Disposal of PFAS Waste
Additional PFAS Resources                 

Remediation Roundtable PFAS Updates

DEEP hosts a Remediation Roundtable three times a year to provide an open forum for the exchange of ideas and information on environmental site cleanup programs in Connecticut. The forum is open to anyone, but targets Licensed Environmental Professionals (LEPs), environmental attorneys, and private sector industry representatives in particular. The DEEP Remediation Division first presented on PFAS at the Remediation Roundtable in June 2017. Since the release of the PFAS Action Plan in November 2019, DEEP has provided a standing PFAS update at each meeting. Copies of these PFAS-specific presentations are provided below.

Remediation Roundtable PFAS Presentations
2023
2022
2021
2020
Spring

March 21

 March 22
 March 23 March 17
Summer
 June 27 June 21 June 22 July 21
Fall
 October 24 October 25 October 5 October 13

PFAS Sampling Guidance

Consider Whether PFAS is a Contaminant of Concern

Environmental professionals must consider whether emerging contaminants, including PFAS, are constituents of concern (COCs) when evaluating Phase I information.  Phase I evaluation of PFAS will help avoid uncertainty, audits, and unanticipated work in the future.  If PFAS are contaminants of concern (COCs) based on site history or operations, they must be included in site characterization.

For information on current and historical uses of PFAS, environmental professionals are encouraged to review resources including, but not limited to:

Reliance on Safety Data Sheets or anecdotal reports is not sufficient to preclude testing for PFAS, as many Safety Data Sheets will not identify PFAS as ingredients if they comprise less than 1% of the product, or if they are considered a “trade secret.” 

Sample Collection Precautions

DEEP encourages environmental professionals to exercise care when sampling for PFAS to avoid cross-contamination of samples. Several states and organizations have prepared guidance on sample collection and analysis procedures.

PFAS Analytical Methods

PFOS chemical structureUse EPA analytical methods for PFAS analysis of potable water and environmental media where they exist. PFAS research is on-going and new analytic methods remain under development. DEEP encourages environmental professionals to refer to the following resources for additional sampling and analysis protocols:

PFAS Analytical Methods Development and Sampling Research | US EPA - comprehensive list of analytical methods for testing different matrices

Department of Defense’s Quality Systems Manual (Version 5.4 2021)

The DPH Environmental Laboratory Certification Program has certified labs for certain PFAS methods and are expected to certify environmental laboratories for additional EPA analytical methods for PFAS.    

PFAS Results Reporting

DEEP requests that the full list of PFAS included in the particular laboratory method utilized for analysis be analyzed for and reported, not only the PFAS chemicals for which DPH and DEEP have established criteria. 

Science surrounding PFAS is continually evolving, including toxicological information for additional substances. Reporting the full list of PFAS associated with a method can assist in source identification and design of treatment systems, as well as avoid the extra time and cost of repeated sampling if a narrow list of PFAS is initially used.

Drinking Water (Potable Water) Analysis

EPA Method 533, which analyzes for 25 PFAS, is DEEP's preferred method for drinking water analysis.  All 10 PFAS with Drinking Water Action Levels are included in this method.  EPA Method 537.1, which reports 18 PFAS, is also an acceptable method, however this method includes only 9 of the 10 PFAS with established Drinking Water Action Levels; PFBA is not included in Method 537.1.  

The CT DPH Environmental Laboratory Certification Program (ELCP) maintains a list of Laboratories Certified to Test Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic acid (PFOA) in drinking water. A DPH ELCP certified laboratory must be used when analyzing samples for submission to DEEP. 

Analysis of Non-Potable Water and Other Aqueous Matrices (groundwater, surface water, and wastewater)
  • EPA Draft Method 1633 – 40 PFAS, isotope dilution: Refer to Accredited Labs Search – Environmental Data Quality Workgroup search site for DOD ELAP accredited labs for Draft Method 1633
  • EPA Method 8327 – 24 PFAS, direct inject/aqueous, external standard: Recommended to be used as a screening method and should not be used for confirmatory sampling.
Analysis of Other Environmental Matrices (soil, biosolids, sediment, landfill leachate, and fish tissue)
  • EPA Draft Method 1633 – 40 PFAS, isotope dilution
  • If EPA Draft Method 1633 is not available, EPA Method 537 rev. 1.1 or 537.1, modified to incorporate isotope dilution, may be used with caution. Use these methods in conjunction with most recent version of the Department of Defense’s Quality Systems Manual, Table B-15 for QA/QC.
Total Oxidizable Precursor (TOP) Assay

Though not an EPA method, the TOP assay may be useful in determining the presence of additional PFAS mass for evaluating contaminant fate and transport or treatment system design.

PFAS Remediation Criteria

The Remediation Standard Regulations do not contain numeric cleanup standards for emerging contaminants including PFAS, but do require remediation using the procedures for Additional Polluting Substances (APS).  APS Criteria for PFAS are available for use upon request using the APS Fast Track Form for the PFAS listed in the table below.  APS criteria for PFAS are in the process of being updated to reflect changes to DPH’s Drinking Water Action Levels for PFAS in June 2022 and June 2023.

Remediation Standard Criteria
Criterion
(Applies to the sum of 
PFOA, PFOS, PFNA, PFHxS & PFHpA)
 Residential Direct Exposure 1.35 mg/kg
 Industrial/Commercial Direct Exposure 41 mg/kg
GA Pollutant Mobility 1.4 ug/kg
GB Pollutant Mobility 14 ug/kg
Groundwater Protection 70 ng/L
Surface Water Protection In Development

Environmental professionals may also develop and propose APS or site-specific criteria using Appendix G of the RSRs, which will require additional approvals from DEEP and DPH. Please note the review process will take substantially longer than approval of the APS Fast Track Form. If other PFAS beyond those included in the above APS criteria list are detected, please contact DEEP for further information and guidance.  

CT PFAS Drinking Water Action Levels

As of June 2023, CT DPH has established drinking water Action Levels for a total of ten PFAS.  Action Levels are established based upon review of the most current toxicological information.  Drinking water Action Levels may be established for additional PFAS compounds or these actions levels may be adjusted in the future as new information becomes available. 

Chemical Contaminant
Abbreviation(s)
CT Action Level
(ng/L, ppt)
Analytical Method
Date of Revision
6:2 chloropolyfluoroether sulfonic acid1
 6:2 Cl-PFESA or F-53B major 2 EPA 533 or 537.1 2023
8:2 chloropolyfluoroether sulfonic acid1 8:2 Cl-PFESA or F-53B minor 5 EPA 533 or 537.1 2023
Hexafluoropropylene oxide-dimer acid HFPO-DA; GenX 19 EPA 533 or 537.1 2023
Perfluorobutane sulfonic acid PFBS 760 EPA 533 or 537.1 2023
Perfluorobutanoic acid PFBA 1800 EPA 533 2023
Perfluorohexane sulfonic acid PFHxS 49 EPA 533 or 537.1 2022
Perfluorohexanoic acid PFHxA 240 EPA 533 or 537.1 2023
Perfluorooctane sulfonic acid PFOS 10 EPA 533 or 537.1 2022
Perfluorooctanoic acid PFOA 16 EPA 533 or 537.1 2022
Perfluorononanoic acid PFNA 12 EPA 533 or 537.1 2022

1 EPA Methods 533 and 537.1 refer to 6:2 Cl-PFESA as 9-chlorohexadecafluoro-3-oxanonane-1-sulfonic acid (9Cl-PF3ONS) and 8:2 Cl-PFESA as 11-chloroeicosafluoro-3-oxaundecane-1-sulfonic acid (11Cl-PF3OUdS).

For additional information visit the DPH PFAS Webpage. 

PFAS Release Reporting

DEEP’s Release Reporting Regulations specifically require that a release of any quantity of liquid containing any PFAS in any amount be reported [RCSA Sec. 22a-450-2(b)(1)(K)]. Releases should be reported to DEEP's Emergency Response Unit 24 hours a day at 866-DEP-SPIL (866-337-7745) or 860-424-3338.

DEEP also requires reporting of firefighting foam, including newer PFAS-free “Green” foam, if it was deployed from fire apparatus or a fixed building or hangar fire suppression system that currently or previously contained aqueous film-forming foam (AFFF) or any other firefighting foam containing intentionally added PFAS (e.g., AR-AFFF, fluoroprotein foams).

Significant Environmental Hazards and PFAS

Reporting of Significant Environmental Hazards for PFAS, as well as other substances that do not have promulgated criteria listed in the Remediation Standard Regulations, is required specifically under CGS Section 22a-6u(c).

After July 1, 2015, if a technical environmental professional (TEP) in the course of investigating and remediating pollution on or emanating from a parcel determines pollution has affected a public or private drinking water supply well with any substance from the release for which there is no RSR criterion,

  • TEP shall notify client and owner of property within 7 days.
  • Owner of parcel that is the source of pollution to a drinking water well shall, within 30 days:
    1. Perform confirmatory sampling of well and submit report to Commissioner with a plan for further action, and
    2. Notify Commissioner in writing (SEH notification form)

If PFAS is detected in a public or private drinking water supply well during water testing that is NOT associated with a site investigation or remedial activity, filing of a Significant Environmental Hazard Notification is NOT required.

However, in order to protect public health, DEEP encourages any detection of PFAS in drinking water,  especially if PFAS exceeds one or more of Connecticut’s PFAS Drinking Water Action Levels, be reported to DEEP (DEEP.PFAS@ct.gov) and DPH (DPH.EmergingContaminants@ct.gov) for follow-up action.

Disposal of PFAS Waste

PFAS waste is regulated in Connecticut as a Non-RCRA Hazardous or Connecticut Regulated Waste, using the following waste codes:

  • CR04 for waste chemical liquids

  • CR05 for waste chemical solids

In October 2021, EPA announced plans to initiate the rulemaking process to propose adding four PFAS chemicals as RCRA Hazardous Constituents under Appendix VIII -- perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorobutane sulfonic acid (PFBS), and GenX. DEEP will follow EPA developments with respect to future RCRA hazardous waste and constituent regulation of PFAS.

Currently, Connecticut has no authorized PFAS-contaminated waste treatment or disposal facilities. DEEP recommends that any out-of-state waste disposal facility be contacted for acceptance guidelines regarding PFAS. Although PFAS is not a hazardous waste in Connecticut, it might be regulated as a hazardous waste in the host state and require a federal manifest.

Environmental professionals may also consult EPA’s Interim Guidance on Destroying and Disposing of Certain PFAS and PFAS-Containing Materials, dated December 2020. This document is scheduled to be updated by EPA by December 2023.

Additional Resources

General PFAS Information
Health Effects of PFAS
Guidance from Other States

Contact Information

For additional questions, please email DEEP.PFAS@ct.gov.

Related Webpages

 

Content last updated December 22, 2023.