On Monday, October 17th, 2022, the New Jersey Department of Environmental Protection (NJDEP) Contaminated Site Remediation & Redevelopment Program (CSRRP) issued an announcement regarding the posting in the October 17, 2022 New Jersey Register of new Soil Remediation Standards for four types of per- and polyfluoroalkyl substances (PFAS): PFNA, PFOA, PFOS and GenX.
PFAS substances have been used for decades within industrial processes, certain types of firefighting foams, and consumer products like fabric protectors. These substances have been found in New Jersey soil and ground water, including, but not limited to, domestic potable wells and other environmental media such as surface water, sediment, and air.
Initially, NJDEP issued Ground Water Quality Standards (N.J.A.C. 7:9C) for PFNA, PFOA, and PFOS during 2018 to 2020. Until now, there were no soil remediations standards for these PFAS. PFAS will now be included in the evaluation of potential for soil contamination and remediation at properties currently or in the future. This will most likely result in increased costs for site remediation.
Sites that will require the investigation/remediation of PFAS in soil will need to identify the affect on their compliance requirements including the regulatory time-frames.
As noted by NJDEP:
Additional investigation of the extent of environmental contamination by PFNA, PFOA, PFOS, and GenX is ongoing. The nature of these chemicals, including their toxicity, bioaccumulation, and potential health effects, indicates the need for interim remediation standards, so that PFNA, PFOA, PFOS, and GenX that are present in soil can be investigated and remediated to protect public health.
Effective immediately, the new soil remediation standards are as follows:
| Containment | CAS No. | Soil Remediation Standard: Ingestion-Dermal Residential (mg/kg)¹ | Soil Remediation Standard: Ingestion-Dermal Nonresidential (mg/kg)¹ | Soil Remediation Standard: Migration to Groundwater (mg/kg)¹ | Soil Leachate Remediation Standard: Migration to Groundwater (µg/L)² |
| Perfluorononanoic acid (PFNA) | 375-95-1 | 0.047 | 0.67 | AOC/Site-Specific³ | 0.26 |
| Perfluorooctanoic acid (PFOA) | 335-67-1 | 0.13 | 1.8 | AOC/Site-Specific³ | 0.28 |
| Perfluorooctane sulfonate (PFOS) | 1763-23-1 | 0.11 | 1.6 | AOC/Site-Specific³ | 0.26 |
| Hexafluoropropylene oxide dimer acid and its ammonium salt (GenX) | 13252-13-6 & 62037-80-3 | 0.23 | 3.9 | N/A⁴ | N/A⁴ |
1mg/kg is equivalent to parts per million (ppm).
2µg/L is equivalent to parts per billion (ppb).
3To be calculated using Synthetic Precipitation Leachate Procedure (SPLP) and the Department’s PFAS SPLP Calculator.
4Not available because there currently is no established Ground Water Remediation Standard (GWRS) to calculate soil and soil leachate remediation standards for the migration to ground water exposure pathway. The NJDEP recommends delineating to the Laboratory Reporting Limit when investigating GenX in soil for the migration to ground water exposure pathway until a GWRS is established for GenX.
We Can Help
For over 35 years, Whitman has helped clients with the investigation, remediation and regulatory compliance for sites under NJDEP programs. This has included cases where NJDEP has issued new remediation related standards.
Contact
If you have any questions or would like to learn more, please contact:
Michael Metlitz, LSRP
Principal
mmetlitz@whitmanco.com
(732) 390-5858
Posted on October 19th, 2022
