Facilities selected for self-reporting or monitoring were chosen based on a list of 28 drinking water systems that the Virginia Department of Health notified DEQ prior to September 1 of having PFAS levels that exceed the maximum contaminant levels set by the EPA. For each of those 28 drinking water systems the area that may affect the source water was determined. For surface water systems the area was the entire watershed upstream of the intake for the drinking water facility. For groundwater systems the area was a three-mile radius from the well.

DEQ then identified all VPDES permittees, Significant Industrial Users (SIUs) based on activity or facility type, fire training facilities, airports, landfills, and other potential sources of PFAS that fall within the areas that may influence the source water. DEQ compared the VPDES permittees and SIUs self-reported Standard Industrial Classification (SIC) or North American Industry Classification System (NAICS) code against a list prepared by the EPA of PFAS Handling industrial sectors and, as required by statute, the code for industrial launderers. The VPDES permittees and SIUs that both had an industrial code of interest and could influence the source water received letters requiring self-reporting use or manufacture of PFAS and monitoring for PFAS in waste streams. Fire training facilities, airports, and active landfills were cross checked to see if they have an VPDES permit and those without were assessed on a case-by-case basis.

Providing an exhaustive list for which products contain PFAS is impossible. PFAS are present in a wide variety of products and there are hundreds of uses for thousands of individual PFAS chemicals. PFAS or PFAS-containing substances are often used as a product ingredient or as a production process aid or additive, such as wetting agents, fume suppressants, photoresists, etchants, cleaners, coatings, surfactants, or flame retardants. Consider looking to see if an industrial trade group has already compiled a list of the types of products where PFAS may be used in your industry. When reading product information and labels, look for terms like “fluorinated surfactant,” “fluorosurfactant,” and chemicals with “fluoro” in their name.

Note:  Only the intentional use of PFAS or PFAS-containing substances needs to be self-reported. The use of manufacturing equipment that contains PFAS does not need to be self-reported.

Total PFAS can be several different things depending on the context. In the case of the Self-Reporting Form, Total PFAS means the total amount of any PFAS used and/or manufactured by your facility.

One starting place to find a laboratory to perform testing is to use the list of labs accredited by the Virginia Division of Consolidated Laboratory Services. Their list of accredited labs can be found on their website: https://dgs.virginia.gov/division-of-consolidated-laboratory-services/certification-accreditation/find-a-lab/

Use the list Accredited Commercial Laboratories is found in a spread sheet under the link “Accredited Commercial Laboratories under 1VAC30-46 with accreditation detail.” To get the list of applicable labs Use the FILTER [arrow in column header] to select the Matrix as “NON-POTABLE WATER” the Method as “EPA 1633” and the Analyte as your PFAS of choice.

Note: DEQ does not require using an accredited lab, just the use of EPA Method 1633 for performing the laboratory analysis.

Method 1633 is a sensitive test, capable of measuring 1 ng of some PFAS in 1 L of water. As a result, care must be taken when sampling for PFAS to minimize the chance of contamination. When sampling for PFAS follow all instructions and guidance from the testing lab. Additionally, consider the following best practices when sampling:

• Work in a two-person team utilizing a clean hands/dirty hands division of labor. The team member in the “clean hands” role is responsible for the activities that must be PFAS free like collecting the sample and handling the blanks. The second person in the “dirty hands” role is responsible for all other duties like turning sampling spigots and pumps on and off, documenting the sampling event, etc.
• Wear well washed clothes particularly avoiding products treated for or marketed as dirt/stain/water resistant or waterproof.
• Do not apply personal care products like sunscreen and insect repellent near the sampling area. Avoid products you do not know to be PFAS free, note that product labels containing “natural” or “organic” do not mean the product if PFAS free. Michigan’s “General PFAS Sampling Guidance” document contains a list of sunscreens and insect repellents previously tested to be PFAS free.
• Do not use sampling equipment that contains PFAS compounds that sample will contact like: Polytetrafluoroethylene (PTFE) [Brand names Teflon® and Hostaflon®], Polyvinylidene fluoride (PVDF) [Brand name Kynar®], Fluorinated ethylene propylene (FEP) [Brand name Teflon® FEP, Hostaflon® FEP, Neoflon®].

For additional guidance, you can review DEQ’s Quality Assurance Project Plan from its PFAS sampling efforts, which is linked below. Much of the information is specific to DEQ’s PFAS monitoring processes, but you may find the general monitoring process outlined in the QAPP, the PFAS sampling guidelines (Appendix A), and the PFAS sample shipping protocols (Appendix D) to be relevant and useful.