On March 13, 2019, new Interim Specific Groundwater Quality Criteria (GWQC) were established by NJDEP for Perfluorooctanic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS), both of which are per-polyfluoroalkyl substances (PFAS). There is already an existing Specific NJDEP GWQC for the PFAS chemical Perfluorononanoic Acid (PFNA). There are many more compounds in this contaminant group but PFOA, PFOS and PFNA are the only three (3) that have current NJDEP GWQC. Based on literature issued by the ITRC, PFOA and PFOS compounds appear to be the most widespread among the PFAS compounds.
The PFAS family consists of more than 3,000 chemicals used in non-stick coatings, water resistant products, firefighting foams, and numerous other materials. Major manufacturing sources of PFAS include textiles and leather, paper products, metal plating and etching, wire manufacturing, industrial surfactants, resins, molds and plastics, photolithography and semi-conductor manufacturing. Places where firefighting foams were manufactured/discharged, wastewater treatment plants and landfills are also considered to be major potential sources of PFAS in the environment.
The NJDEP is requiring that active SRP sites and sites that received Limited Restricted Use or Restricted Use RAOs after March 13, 2019 be evaluated for PFAS contaminants no later than May 7, 2019. Sites that received unrestricted RAOs prior to March 13, 2019 are not required to evaluate for PFAS.
Sites that have not performed the required evaluation for PFAS by May 7, 2019 or do not complete the investigation and/or cleanup of PFAS within the existing SRP timeframes are considered to be out of compliance.
Timeframe extensions are being granted by NJDEP for investigation of these interim specific contaminants.
The following links provide additional information:
JMC can complete the required site evaluation for PFAS and conduct any required investigation in response to potential PFAS contamination. Please call or email us to discuss your specific situation regarding these changes or if you have questions regarding how this new regulation may affect your site.