On Friday, MassDEP proposed a number of revisions to the Massachusetts Contingency Plan, including reporting and cleanup standards for PFAS.  The proposed GW-1 standard, applicable to current and potential drinking water source areas, would be 20 parts per trillion for the sum of six PFAS compounds (PFDA, PFHpA, PFHxS, PFOA, PFOS, and PFNA) – significantly more stringent than the 70 ppt guideline for the sum of five PFAS compounds currently in effect.

Of course, the standards are less stringent where drinking water is not affected, but even some of those numbers are pretty low.  For example, the standard for S-3 soils, those that can be subject to activity and use limitations and would be unlikely to present significant exposures, would be 400 parts per billion.  How many sites in Massachusetts have soil concentrations of the six PFAS above 400 ppb?  Every landfill?  Every airport?  It’s got to be quite a number.  If these regulations are finalized, such facilities are going to have to do something about the PFAS, even if an AUL is in place, unless a Method 3 risk assessment yields some different results.

Who said Superfund was dead?