5._Field_Sampling_Protocol_for_PFOA-PFOS-PFBS_Guidance_Sampling_Considerations_June_2019.docx

Field Sampling Protocol for Perfluorooctanoic Acid (PFOA), Perfluorooctane sulfonate (PFOS) and Perfluorobutane Sulfonate (PFBS)

Below are procedures to be followed when field sampling for analysis of PFOS/PFOA and PFBS.

Why do we need this special sampling guidance?

PFAS are a class of manufactured compounds that are extensively used to make everyday items more resistant to stains, grease, and water. These chemicals have been used in a variety of industrial, commercial and consumer products. Some of these products could be present and/or used during a routine sampling event, such as plastic bags and bottles, waterproof clothing, detergents, and waterproof pens and paper. Because the EPA has established health advisory levels that are very low concentrations (70 parts per trillion) for PFOA and PFOS, the use of these products could possibly contaminate the samples during sample collection. This includes what is used to prepare the sampling site, what is used to collect the sample, what is used to clean the sampling equipment, what the sample is collected in, and how the sample is shipped. Proper procedures are necessary to insure the quality and integrity of the samples. This guidance will provide steps to take to help you avoid these potential sources of contamination.

FIELD PROCEDURES/CONSIDERATIONS

The following are procedures and considerations to make during field sampling activities at locations with potential PFOS/PFOA/PFBS compounds. A summary of prohibited and acceptable items used when sampling for PFOS/PFOA/PFBS is included in Table 1. A checklist, provided as Attachment 1, should be used daily by the Field Manager prior to the commencement of fieldwork to ensure the field team is in compliance with this protocol.

Field Equipment

· Do not use Teflon®-containing materials (e.g., Teflon® tubing, bailers, tape, plumbing paste, or other Teflon® materials) since Teflon® contains fluorinated compounds.

· Can be used. High-density polyethylene (HDPE) and silicon materials are acceptable for sample collection, as they do not contain fluorinated compounds. Samples may not be stored in containers made of LDPE materials because PFOS/PFOA can stick to LDPE and bias sample results low.

· Use peristaltic pumps for groundwater sample collection at depths shallower than 25 feet. Use ProActive SS Pumps with polyvinyl chloride (PVC) leads or Geotech SS Geosub pumps for groundwater sample collection at depths greater than 25 feet. These pumps are constructed with stainless steel and will minimize introductions of any PFOS/PFOA and PFBS. However, for groundwater sample depths greater than 150 feet, a Grundfos RediFlo pump (or similar) may be used due to the pumping limitations of stainless steel pumps.

· When using liners to collect soil samples during direct-push technology or during conventional drilling and sampling methodologies, acetate liners are to be used.

· Rite in the Rain© products are the only waterproof field books that may be used. To avoid plastic coating or glue materials, do not use other brands of waterproof field books. If Rite in the Rain© products are not available, field reports will be documented on loose paper secured on masonite or aluminum clipboards (i.e. plastic clipboards, binders, or spiral hard cover notebooks are not acceptable) using a pen or pencil. Sharpies®/markers may also be used.

· Post-It Notes are not allowed on project sites.

· Do not use markers other than Sharpies®markers. Pens will be used when documenting field activities in the field log and on field forms as well as labeling sample containers and preparing the Chain of Custody.

· Preprinted standard (non-weatherproof) Avery sample labels can be used on sample containers. Sample labels will be placed on containers after sampling is complete and container lids are in place to prevent possible cross contamination.

· Do not use chemical (blue) ice packs during the sampling program. This includes the use of ice packs for the storage of food and/or samples.

Field Clothing and Personal Protective Equipment

· Do not wear water resistant, waterproof, or stain-treated clothing during the field program. Field clothing made of synthetic and natural fibers (preferably cotton) are acceptable. Field clothing should be laundered without the use of fabric softener. Preferably, field gear should be cotton construction and well laundered (i.e., washed a minimum of 6 times prior to use after purchase). New clothing may contain PFOS/PFOA related treatments. Do not use new clothing while sampling or sample handling.

· Do not wear clothing or boots containing Gore-Tex™ during the sampling program as it contains a PFOS/PFOA membrane.

· Safety footwear will consist of steel-toed boots made with polyurethane and PVC, untreated leather boots, or well-worn leather boots. Newer leather boots may be worn if they are covered with polypropylene, polyethane, or PVC boot covers.

· Disposable nitrile gloves must be worn at all times. Further, a new pair of nitrile gloves shall be donned prior to the following activities at each sample location:

· Decontamination of re-usable sampling equipment;

· Prior to contact with sample bottles or water containers;

· Insertion of anything into the well (e.g., HDPE tubing, HydraSleeve bailer, etc.);

· Insertion of silicon tubing into the peristaltic pump;

· Completion of monitor well purging, prior to sample collection;

· Handling of any QA/QC samples including field blanks and equipment blanks;

· After the handling of any non-dedicated sampling equipment, clipboards, charts, items carried or staged from site to site (sheeting), contact with non- decontaminated surfaces, or when judged necessary by field personnel.

Sample Containers

· Different laboratories may supply sample collection containers of varying sizes dependent on the type of media to be sampled (e.g., soil, groundwater, etc.). All samples should be collected in polypropylene or HDPE bottles. The screw cap will be made of polypropylene or HDPE and may be lined or unlined. However, if lined, the liner may not be made of Teflon® or contain PFAS compounds.

· Container labels will be completed using a pen after the caps have been placed back on each bottle.

· Glass sample containers are not to be used due to potential loss of analyte through adsorption.

Wet Weather

· Field sampling occurring during wet weather (e.g., rainfall and snowfall) should be conducted while wearing appropriate clothing that will not pose a risk for cross- contamination. Teams will avoid synthetic gear that has been treated with water-repellant finishes containing PFOS/PFOAs. Use rain gear made from polyurethane, vinyl, and wax or rubber-coated materials.

· Teams should consider the use of a pop-up canopy, which can be erected overtop of the sample location and provide shelter from the rain. It should be noted that the canopy material is likely a treated surface and should be handled as such; therefore, gloves should be worn when setting up and moving the tent, changed immediately afterwards and further contact with the tent should be avoided until all sampling activities have been finished and the team is ready to move on to the next sample location.

Equipment Decontamination

· Field sampling equipment, including oil/water interface meters and water level indicators, and other downhole equipment used at each sample location, will require cleaning between uses. Alconox® and Liquinox® soap is acceptable for use since the Safety Data Sheets do not list fluoro-surfactants as an ingredient. However, Decon 90 will not be used during decontamination activities. Water used for the final rinse during decontamination of sampling equipment will be laboratory certified “PFOS/PFOA-free” water.

For larger equipment (e.g., drill rig and large downhole drilling and sampling equipment), decontamination will be conducted with potable water using a high-pressure washer and then rinsed using potable water.

Personnel Hygiene

· Field personnel will not use cosmetics, moisturizers, hand cream, or other related products as part of their personal cleaning/showering routine on the morning of a sampling event, unless the products are applied to a part of the body that will be coved by clothing. These products may contain surfactants and represent a potential source of PFOS/PFOAs.

· Many manufactured sunblock and insect repellants contain PFOS/PFOAs and should not be brought or used on-site. Sunblock and insect repellants that are used on-site should consist of 100% natural ingredients, unless previously vetted by the project chemist. A list of acceptable sunscreens and insect repellents is provided in Table 1.

· For washroom breaks, field personnel will leave the exclusion zone and then remove gloves and overalls. Field personnel should wash as normal with extra time for rinsing with water after soap use. When finished washing, the use of a mechanical dryer is preferred and the use of paper towel for drying is to be avoided (if possible).

Food Considerations

· No food or drink shall be brought on-site, with the exception of bottled water and hydration drinks (i.e., Gatorade® and Powerade®), and only be allowed within the staging area.

Visitors

· Visitors to the investigation area are asked to remain outside of the exclusion zone during sampling activities.

SAMPLING ENVIRONMENTAL MEDIA

Collecting samples is an important site characterization activity, and can be used to determine the nature and extent of contamination, to identify hazardous substance source areas, and to determine the geotechnical, hydrogeologic, physical, and chemical properties of a site. Sampling strategies for PFOS/PFOA compounds will be determined and documented before initiating sampling. Field conditions at proposed sampling locations may preclude collection at one or more predetermined sampling points. And additional sampling may be required if unexpected subsurface conditions are observed during the course of the sampling. Proper sampling techniques, proper selection of sampling equipment, and proper decontamination procedures will eliminate cross- contamination and the introduction of contaminants from external sources.

Drinking water samples must be analyzed by EPA Method 537 rev1.1, unless another method is approved for use by AFCEC/CZTE or the contracting service center. For all other media, including groundwater and surface water, the requirements in Table B-15 of the DoD Quality Systems Manual (QSM) must be met, and a laboratory with current accreditation under the DoD Environmental Laboratory Accreditation Program to that method (PFOS/PFOA by LC-MS-MS Compliant with QSM Table B-15) must be used. Stage IV laboratory data packages are required deliverables. Data Validation at Stage IV must be performed to confirm any data results that exceed the LHA in aqueous media.

Soil conditions can vary widely at remediation sites. Such variations can affect the rate of contaminant migration through the soil. Therefore, it is important that detailed records be maintained during sampling, particularly with respect to the sample location, depth, color, odor, lithology, hydrogeology, and readings derived from field monitoring equipment.

· Soil. Collect samples as follows: one shallow soil (approximately 0-1’ below grade); one mid-level sample approximated from depth to initial groundwater; and one sample from directly above the identified groundwater table in the vadose, unsaturated zone of the lithologic column. Additionally, a soil sample should be collected at the mid-depth of the boring at any identified lithologic/permeability changes, since significant clay layers identified in any historic soil boring records near the site may act as an aquitard to surface water percolation.

Surface and shallow subsurface soil samples shall be described utilizing the Unified Soil Classification System and / or ASTM guidance D2487 Standard Practices for Classification of Soils for Engineering Purposes (Unified Soil Classification System), unless otherwise specified by the work plan.

FIELD EQUIPMENT

Equipment and supplies used to collect, document, and package surface or subsurface soil samples may include, but is not limited to, the following items:

· Nitrile gloves;

· Stainless steel spoons/trowels;

· Stainless steel hand auger;

· Stainless steel split spoon, split barrel, or continuous sampler;

· Stainless steel bowls/pans;

· Field tablets, logbooks, and boring logs (Rite in the Rain© products are the only waterproof field books that may be used, no other water resistant paper is allowed);

· Pens;

· Paper towels;

· Appropriate decontamination equipment;

· Appropriate personnel protective equipment and safety equipment as specified in the Health and Safety Plan and in other SOPs;

· Sample cooler with ice (no blue ice);

· Sample containers (no LDPE or glass) and labels;

· Bubble wrap;

· Chain-of-Custody forms;

· Munsell Soil Color charts;

· Grain size charts;

· Hand lens;

· Brass sleeves;

· Brass caps;

· Acetate liners;

· Ziplock freezer bags;

· Stainless steel deionized water spraying devices;

· Non PFC plastic sheeting; and

· Non PFC tape.

All field equipment and supplies will be considered using the Tiered Approach provided in Table 2, Field Sampling Protocols to Avoid Cross Contamination of Perfluorinated Compounds, prior to use onsite.

DECONTAMINATION

Downhole drilling and sampling equipment (including but not limited to drill pipe, drive casing, drill rods, bits, tools, non-disposable bailers, etc.) will be thoroughly decontaminated before mobilization to each investigation area and between borings or wells at each sampling location or as required in work plans. Before collecting samples, all sampling devices shall be decontaminated. If dedicated or disposable equipment is used, it will be rinsed with deionized water where applicable. Mobile decontamination supplies should be available so that equipment can be decontaminated in the field. Each piece of sampling equipment shall be decontaminated before initiation of sampling operations and between each sample location and interval. PFOS/PFOA-free decontamination solutions shall be replenished between sampling locations as needed. Spent decontamination fluids will be containerized, properly labeled and appropriately disposed of according to Air Force investigation derived waste (IDW) guidance.

Table 1. Summary of Prohibited and Acceptable Items for Sampling of PFOS/PFOA Compounds

Field Equipment

Teflon® containing materials (Teflon® synonyms include: Polytetrafluoroethylene; Poly[ethylene tetrafluoride]; Polytetrafluoroethene; Tetrafluoroethene polymer; Tetrafluoroethylene homopolymer; Ethene; tetrafluoro-; and homopolymer. Commercial names include: PTFE; Aflon; Algloflon; Chromosorb T; Fluon; Fluo-kem; Fluoroflex; Fluoroplast 4; Halon G 80; Heydeflon; Polifen; Politef; and Tarflen) High-density polyethylene (HDPE) and Low density polyethylene (LDPE) materials

Sharpies®, pens

Post-It Notes

Excel Purity Paste TFW Multipurpose Thread Sealant Vibra-Tite Thread Sealant Gasoils NT Non-PTFE Thread Sealant Bentonite

Equipment with Viton Components (need to be evaluated on a case by case basis, Viton contains PTFE, but may be acceptable if used in gaskets or O- rings that are sealed away and will not come into contact with sample or sampling equipment.)

Field Clothing and PPE

Cotton construction is recommended for field clothing

Insect Repellents - Jason Natural Quit Bugging Me, Repel Lemon Eucalyptus Insect repellant, Herbal Armor, California Baby Natural Bug Spray, BabyGanics, Deep Woods Off Sunscreen and insect repellant - Avon Skin So Soft Bug Guard Plus – SPF 30 Lotion Sunscreens - Alba Organics Natural Sunscreen, Yes To Cucumbers, Aubrey Organics, Jason Natural Sun Block, Kiss my face, Baby sunscreens that are “free” or “natural”.

Insect Repellents - Jason Natural Quit Bugging Me, Repel Lemon Eucalyptus Insect repellant, Herbal Armor, California Baby Natural Bug Spray, BabyGanics, Deep Woods Off Sunscreen and insect repellant - Avon Skin So Soft Bug Guard Plus – SPF 30 Lotion

Sample Containers

Rain Events

Equipment Decontamination

Food Considerations

Table 2. Tiered Approach

A Tier 1 products will undergo the closest scrutiny. It may be necessary to have Tier 1 products analyzed for PFCs to confirm that a specific batch or lot number does not contain PFCs. Alternate products will need to be evaluated/used if PFCs are identified in the product.

B SDS Check: To evaluate product SDS and/or manufacturing specs, check if the product contains anything with “fluoro” in the name or the acronyms TPE, FEP, ETFE, and/or PFA. If fluorinated compounds are not listed in the manufacturing specs and/or on the SDSs, product can be used.

3 June 2019

Attachment 1 to SOP Daily PFOS/PFOA Protocol Checklist Field Clothing and PPE:

· Field crew in compliance with Tables 1 and 2, SOP AFW-01

· Field crew has not used fabric softener on clothing

· Field crew has not used cosmetics, moisturizers, hand cream, or other related products on exposed body parts this morning

· Field crew has not applied unacceptable sunscreen or insect repellant

Field Equipment:

· No Teflon® containing materials on-site

· All sample materials made from stainless steel, HDPE, acetate, silicon, or polypropylene

· No waterproof field books on-site other than Rite in the Rain products

· No plastic clipboards, binders, or spiral hard cover notebooks on-site

· No adhesives (Post-It Notes) on-site

· Coolers filled with regular ice only. No chemical (blue) ice packs in possession

Sample Containers:

· All sample containers made of HDPE or polypropylene. Samples are not stored in containers made of LDPE

· Caps are lined or unlined and made of HDPE or polypropylene

Wet Weather (as applicable):

· For personnel in direct contact with samples and/or sampling equipment, wet weather gear made of vinyl, polyurethane, PVC, wax or rubber- coated materials only

Equipment Decontamination:

· “PFC-free” water on-site for decontamination of sample equipment

· Alconox and Liquinox to be used as decontamination materials

Food Considerations:

· No food or drink on-site with exception of bottled water and/or hydration drinks (i.e., Gatorade and Powerade) that is available for consumption only in the staging area

If any applicable boxes cannot be checked, the Field Manager shall describe the noncompliance issues and work with field personnel to address noncompliance issues prior to commencement of that day’s work. Corrective action shall be taken and may include removal of noncompliance items from the investigation area or removal of worker offsite until in compliance.