DDW-2025-004716

Utah Division of Drinking Water
Quality Assurance Project Plan
for
Utah’s PFAS Project
Final
Revision No.2.1
Effective February 2024
Utah Division of Drinking Water
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City,Utah 84116
Title:QAPP for Utah’s PFAS Project
Revision Number:2.1RevisionDate:January 2024
Approval Signatures:
____________________________________________________________________________________
Nathan Lunstad,Director Date
Utah Division of Drinking Water
____________________________________________________________________________________
Sarah Page,Lead Water Treatment Specialist Date
Utah Division of Drinking Water
___________________________________________________________________________________
Mark Berger,Monitoring and Standards Section Manager Date
Utah Division of Drinking Water
____________________________________________________________________________________
Eleanor Divver,Quality Process Coordinator Date
Utah Department of Environmental Quality
____________________________________________________________________________________
Sarah Romero,PFAS Project Manager Date
Utah Division of Drinking Water
____________________________________________________________________________________
Kimia Golchin,Database &Quality Assurance Manager Date
Utah Division of Drinking Water
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Title:QAPP for Utah’s PFAS Project
Revision Number:2.1RevisionDate:January 2024
Table of Contents
Section Page
ACRONYMS 4
1.0 PROJECT MANAGEMENT 5
1.1 Title and Approval Page –See Cover Page &Page 1 5
1.2 Table of Contents–See Page 2 5
1.3 Distribution List 5
1.4 Project Organization 6
1.4.1 DDW PFAS Project Manager 6
1.4.2 DDW Database/QA Manager 6
1.4.3 DDW Drinking Water Treatment Specialist 6
1.4.4 Field Technicians 6
1.4.5 Laboratory Partners 6
1.5 Problem Definition/Background 6
1.6 Project/Task Description and Schedule 8
1.7 Quality Objectives and Criteria for Measurement Data 9
1.8 Special Training Requirements/Certification 9
1.9 Documents and Records 10
1.9.3 Laboratory Documentation and Records 11
1.9.4 Final Reports 11
2.0 DATA GENERATION AND ACQUISITION 12
2.1 Sampling Design 12
2.2 Sampling Methods 12
2.3 Sample Handling and Custody 12
2.4 Analytical Methods 12
2.4.1 Field Measurement and Analyses Methods 12
2.4.2 Laboratory Analyses Methods (Off-Site)12
2.5 Laboratory Analysis Quality Control 13
2.6 Instrument/Equipment Testing,Inspection,and Maintenance 13
2.6.1 Field Instruments/Equipment 13
2.6.2 Laboratory Analysis Instruments/Equipment (Off-Site)13
2.7 Instrument/Equipment Testing and Calibration,Inspection,and Maintenance 13
2.8 Inspection/Acceptance Requirements for Supplies and Consumables 13
2.8.1 Field Sampling Supplies and Consumables 13
2.8.2 Laboratory Analyses (Off-Site)Supplies and Consumables 14
2.9 Data Acquisition Requirements (Non-Direct Measurements)14
2.10 Data Management 14
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3.0 ASSESSMENT AND OVERSIGHT 15
3.1 Assessments/Oversight and Response Actions 15
3.2 Reports to Management 15
4.0 DATA REVIEW AND USABILITY 16
4.1 Data Review,Verification,and Validation Requirements 16
4.2 Verification and Validation Methods 16
4.3 Reconciliation with User Requirements 17
FIGURES:18
Figure 1-1.Organization Chart 18
TABLES:20
Table A:Contaminants,Minimum Reporting Levels,and Analytical Methods 20
Table B:U.S.EPA PFAS Interim HALs and Proposed MCLs 21
REFERENCES 22
APPENDICES 23
Appendix A:Sampling Procedure 23
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ACRONYMS
ASTM American Society for Testing and Materials
BIL Bipartisan Infrastructure Law
CMDP Compliance Monitoring Data Portal
COC Chain of Custody
DBPs Disinfection By-Products
DDW Division of Drinking Water
DEQ Utah Department of Environmental Quality
DQI Data Quality Indicators
EC Emerging Contaminants
EDR Electronic Document Repository
EPA U.S.Environmental Protection Agency
FRB Field Reagent Blank
HFPO-DA Hexafluoropropylene Oxide Dimer Acid
ICP Inductively Coupled Plasma
LCS Laboratory Control Sample
MS Matrix Spike
NPWD National Primary Drinking Water Regulation
POE Point-of-Entry
PFAS Per-and Polyfluoroalkyl Substances
PFBS Perfluorobutanesulfonic Acid
PFC Perfluorinated Compounds
PFHxS Perfluorohexane Sulfonic Acid
PFOA Perfluorooctanoic Acid
PFOS Perfluorooctane Sulfonate
PFP PFAS Project
PFNA Perfluorononanoic Acid
ppb Parts Per Billion
PWS Public Water System
QA Quality Assurance
QAPP Quality Assurance Project Plan
QA/QC Quality Assurance/Quality Control
QMP Quality Management Plan
SDWIS Safe Drinking Water Information System
SM Standard Methods for the Examination of Water and Wastewater
SOP Standard Operating Procedure
WIIN Water Infrastructure Improvements for the Nation Act
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1.0 PROJECT MANAGEMENT
1.1 Title and Approval Page –See Cover Page &Page 1
1.2 Table of Contents–See Page 2
1.3 Distribution List
The following is a list of organizations and persons who will receive copies of the approved
QAPP and any subsequent revisions:
Utah Department of Environmental Quality
195 N 1950 W
Salt Lake City,UT 84116
Nathan Lunstad
Director,Division of Drinking Water
[e-mail]
Mark Berger
Monitoring and Standards Section Manager,Division of Drinking Water
[e-mail]
Sarah Page
Drinking Water Treatment Specialist
[e-mail]
Sarah Romero Rivera
PFAS Project Manager,Division of Drinking Water
[e-mail]
Kimia Golchin
Database Manager,Division of Drinking Water
[e-mail]
Eleanor Divver
Quality Process Coordinator,Office of Planning &Public Affairs
[e-mail]
1.4 Project Organization
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The Utah Department of Environmental Quality (DEQ)–Division of Drinking Water (DDW)is Utah’s
designated administrator for the Emerging Contaminants (EC)in Small or Disadvantaged Communities
Grant (SDC)as authorized by the Bipartisan Infrastructure Law (BIL)to address emerging
contaminants.The participating agency is the U.S.Environmental Protection Agency,Region 8 (EPA).
This project is called Utah’s PFAS Project (PFP).This QAPP has been developed in accordance with
Utah DEQ’s approved Quality Management Plan (QMP),revised December 2017.The roles and
responsibilities of those involved in this program are listed below.
See Figure 1-1.Organization Chart
1.4.1 DDW PFAS Project Manager
The DDW PFAS Project (PFP)Manager will be the responsible official for this project,maintaining this
QAPP,overseeing the overall project and budget.They will be responsible for reviewing and approving
field and laboratory data.They will communicate project needs to the Database/QA Manager,DDW
Drinking Water Treatment Specialist,laboratory partners,and DDW leadership when necessary.
1.4.2 DDW Database/QA Manager
The DDW Database/QA Manager will be responsible for assisting the PFP Manager with laboratory
data review and approval.They may provide technical input on electronic data submission and data
validation.They may assist with coordinating laboratory submission of project data.
1.4.3 DDW Drinking Water Treatment Specialist
The DDW Drinking Water Treatment Specialist will be responsible for assisting the PFP Manager with
technical assistance,research and subject expertise.
1.4.4 Field Technicians
The Field Technicians will be responsible for technical and sampling assistance to water systems.
1.4.5 Laboratory Partners
This project does not dictate the use of any specific laboratory.DDW will select laboratories that
demonstrate appropriate quality assurance (QA)elements,including proficiency testing and
matrix-specific quality control (QC)results,to ensure that results are comparable over time and across
laboratories.The laboratory must analyze drinking water for Per-and Polyfluoroalkyl Substances
(PFAS)using U.S.EPA Method 533 or a version of US.EPA Method 537.1 modified for surface water.
DDW anticipates pursuing a lab contract in the future that uses U.S.EPA Method 537.1.Laboratories
must have a National Environmental Laboratory Accreditation Program (NELAP)certification or
equivalent and documented project experience analyzing PFAS.The laboratories will be responsible for
assigning appropriate,qualified laboratory staff to perform the analyses specified in this plan.
1.5 Problem Definition/Background
PFAS in drinking water has received a significant amount of attention in recent years due to rising health
concerns across the United States.As a result,both state and federal government agencies have created
initiatives focused on PFAS in drinking water.
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PFAS are a group of synthetic chemicals that have been in use since the 1940s.PFAS are found in a
wide array of consumer and industrial products.PFAS manufacturing and processing facilities,facilities
using PFAS in production of other products,airports,and military installations are some of the
contributors of PFAS releases into the air,soil,and water.Common uses include foam used to fight fires,
metal plating and coating formulations,polyurethane production,inks,varnishes,and lubricants.They
can be found in cookware,food packaging,ski wax,and water-or stain-resistant fabric treatments.More
than 12,000 PFAS compounds are known to exist,although not all are in current use or production.Due
to their widespread use and persistence in the environment,most people in the United States have been
exposed to PFAS.Evidence shows that continued exposure above specific levels to certain PFAS may
lead to adverse health.
On March 14,2023,EPA announced the proposed National Primary Drinking Water Regulation
(NPDWR)for six PFAS,including perfluorooctanoic acid (PFOA),perfluorooctane sulfonic acid
(PFOS),perfluorononanoic acid (PFNA),hexafluoropropylene oxide dimer acid (HFPO-DA,commonly
known as GenX Chemicals),perfluorohexane sulfonic acid (PFHxS),and perfluorobutane sulfonic acid
(PFBS).The proposed PFAS NPDWR does not require any actions until it is finalized.EPA anticipates
finalizing the regulation by the end of 2023.
The State of Utah is committed to addressing emerging contaminants in their drinking water and
believes that all people deserve the right to clean and safe drinking water.Tests have revealed the
presence of PFAS at a few locations around the state.In 2020,the Utah Department of Environmental
Quality (DEQ)developed a Reconnaissance Sampling Plan with the goal of assessing the potential
impact of PFAS on the health of Utahns.Although no PFAS are known to be manufactured in Utah,
there are industrial processes that may use PFAS in manufacturing.These potential sources were
mapped in proximity to public drinking water wells to compile the first list of target sites.Public
drinking water well sites were selected for sampling based on potential risk of contamination from
known or suspected sources.
Additional testing resources were offered to select water providers to sample their major surface water
sources,since surface water sources are,in general,more vulnerable to contamination.Sampling for
both wells and surface water was conducted on the untreated water source,since normal treatment
processes do not remove PFAS.In all circumstances,results have fallen well below all current advisory
limits for the PFAS measured.If a National Primary Drinking Water Regulation (NPDWR)is finalized
for PFAS,DDW will reevaluate these results.
Utah is proposing to use available funding awarded by the EPA to take a proactive approach to expand
drinking water sampling and to take actions to reduce or remediate possible PFAS exposure in and
around communities that are small or disadvantaged and lack capacity to undertake these activities
independently.Many of these potential contamination sources are located in or near small or
disadvantaged communities that lack the capacity to effectively identify emerging contaminants and
begin addressing potential contamination.Addressing disproportionate exposure to environmental
contaminants is a core component of Utah’s environmental justice goals.
Interpreting data from analysis of PFAS in a variety of environmental sample types can be challenging
due to variations in analytical protocols,quality control types and criteria,and data review procedures
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across laboratories and general ubiquity in the environment.Moreover,PFAS are analyzed at the
parts-pertrillion level,leaving little room between action levels and method detection limits.Stringent
quality control is needed to ensure data quality and reliability to allow information decisions regarding
site specific actions.This document outlines the level of quality control necessary such that any drinking
water sample analyzed and reviewed through the PFP using U.S.EPA Method 537.1 and U.S.EPA
Method 533 can be relied upon for decision making purposes.
1.6 Project/Task Description and Schedule
DDW anticipates available funding will allow around 520 small or disadvantaged Public Water Systems
(PWS)to be sampled and analyzed for PFAS.DDW will sample water in all communities that qualify as
small or disadvantaged at their Point-of-Entries (POEs)and/or sources.After each PWS is sampled and
the data is compiled,DDW will determine which systems have PFAS levels that exceed the current
proposal maximum contaminant levels established by EPA.DDW will reevaluate these levels if a
NPDWR is finalized for PFAS.
In addition,Utah will sample other emerging contaminants,such as manganese and unregulated
Disinfection By-Products (DBPs),to understand the chemicals in PWSs better and address any levels
above what is considered safe by the EPA.DDW anticipates the sampling process will take two years to
complete statewide,but individual water systems may advance more quickly to the planning stages.
Once a PWS has been accepted to participate in the project,the PWS will work with the PFP Manager to
create a sampling plan.The PFP Manager will receive sample bottles from a Laboratory Partner and
then ship them to the participating PWSs or DDW field technicians will take the sample bottles and
sample directly at the PWS.
The PWS or DDW field technicians will collect samples from all drinking water sources and/or POE
using 250 ml HDPE or Polypropylene bottles.See Appendix A for Sampling Procedure.
Laboratory partners will perform the analysis for PFAS (See Section 1.4.5).
The project schedule is as follows:
Activity Date Participants
Finalized Sampling PFAS SOP November 2023 UDEQ
Small or Disadvantaged System
Sampling
2023-2028 UDEQ/Contractors
Finalized PFAS QAPP November 2023 UDEQ
Table 1-1
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1.7 Quality Objectives and Criteria for Measurement Data
This section describes the overall objectives and criteria for measurement for the DDW PFP.
1.7.1 Objectives and Project Decisions
The overall objective for the PFP is to determine drinking water PFAS concentrations at PWS.PWS will
also gain greater awareness of monitoring for the presence of PFAS in drinking water at their PWS.
1.7.2 Action Limits/Levels
After testing is completed,PWSs found to have PFAS at or above 90%of the EPA’s proposed Maximum
Contaminant Levels (MCLs)will be recommended to,within a year,notify their customers of the
results,provide their customers with appropriate educational materials,and complete PFAS remediation.
Once the EPA PFAS MCL rule has been finalized,this policy will be revised to reflect EPA’s
requirements.
See Table B for EPA’s Proposed PFAS MCL.
All public water systems that exhibit PFAS at or above 80%of the EPA’s proposed MCL will be
considered for resampling to verify the detection.Resampling may reduce the potential for analytical
false positives.
1.7.3 Measurement Performance Criteria/Acceptance Criteria
Data generated in this project must be of known and acceptable quality.DDW identified data quality
indicators (DQI)for PFAS sampling parameters.The DQIs include:precision,accuracy/bias,
representativeness,comparability,completeness,and sensitivity.The minimum QA standards required
for the certification of environmental laboratories under Utah Administrative Code R444-14 and under
EPA approved methodologies have been determined to be adequate with regard to the DQIs for this
project.
1.8 Special Training Requirements/Certification
This section describes the training requirements and certifications for personnel of PWS,laboratory
partners,and DDW.
1.8.1 Public Water Systems
DDW will provide training documents and fact sheets for PWSs on the DDW’s project webpage.On-site
training and technical assistance may be provided by the PFP Manager,DDW field technicians,or other
DEQ staff.Training will adhere to EPA’s guidance and protocol once it is established.Training records
and certification will be kept in DDW’s shared drive.
1.8.2 DDW Personnel
PFP Manager and field technicians will review this QAPP and any related documents to understand
DDW’s PFAS sampling procedures and requirements.Training records and certification will be kept in
DDW’s shared drive.
1.8.3 Laboratory Personnel
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Laboratory personnel analyzing drinking water samples will have successfully completed the required
demonstrations of capability for the methods used.The laboratories must use the EPA PFAS drinking
water laboratory methods and Utah approved methods.Laboratories must have a National
Environmental Laboratory Accreditation Program (NELAP)certification or equivalent and documented
project experience analyzing PFAS.
1.9 Documents and Records
This section details the records created during the PFP,as well as their delivery and storage.All records
will be kept per State Records Retention Schedule or EPA Retention Schedule,whichever is longest.
Utah Division of Technology Services backup all its databases on predetermined schedules.
1.9.1 QA Project Plan Distribution
DDW will act as the point of contact for all QAPP distributions.DDW will maintain an updated and
accurate email contact list and will distribute the amended QAPP to the individuals listed in Section 1.3.
1.9.2 Field Documentation and Records
Records generated during this program might include:sampling plans,sampling maps,and pre-printed
forms (such as labels and chain-of-custody forms).All field activities must be conducted according to
the sampling protocols explained in the Sampling Procedure (Appendix A).The PFP Project Manager is
responsible for maintaining updated revisions to the sampling protocols at all times and distributing
updated sampling protocols to program contacts as needed.All documentation generated by the
sampling program will be kept on file by DDW.
1.9.2.1 Sampling Plans
Sampling plans will be used to determine the number and location of samples in order to guide sampling
activities.PWSs with the PFP Manager’s guidance and assistance will create sampling plans using a
template developed by DDW.This template can be accessed online or may be provided as a physical
paper copy to PWSs.Instructions on the project website will help guide creation of sampling plans.The
sampling plan will be reviewed and approved by the PFP Manager.Approved sampling plans will be
stored by DDW on D2 or Google Drive.At a minimum,the information to be recorded in a sampling
plan for each PWS includes:
-Sampling Location (POE or Source)
-Sampling Description (Facility Description)
1.9.2.2 Sampling Maps
Sampling Maps will show the location of each source or POE to be sampled.The PFP Manager will
approve and use these maps when evaluating sampling.Approved sampling maps will be stored by
DDW on an electronic document repository (EDR)or Google Drive.These maps will contain the
following information:
-Date created
-Sampling Location (POE or Source)
-Relevant Facility Locations
1.9.2.3 Chain-of-Custody Forms
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Samplers will fill out Chain of Custody (COC)forms during sampling.The forms will be submitted to
the laboratory along with the samples.Certified laboratories are required to maintain records of COC
forms under R444-14.DDW will keep copies of submitted COC forms on EDR.Key information from
COC forms and results reports will be on DDW’s SDWIS through manual entry by DDW staff.
1.9.3 Laboratory Documentation and Records
Laboratories will keep records of COCs and results of analyses in accordance with the requirements of
R444-14.Laboratories will submit the results of analyses to DDW via CMDP.Additionally,laboratories
will provide the results as a pdf report and an Excel spreadsheet via email.These emails will be archived
so they can be reviewed later if necessary.
1.9.4 Final Reports
DDW will recommend to PWS to make any detectable results in the finished water available to the
public through their annual consumer confidence report.DDW will keep a list of PWS that have any
detectable results.If PFAS is included in their annual consumer confidence report,DDW staff will
review these reports to ensure that the results given match the official results submitted to DDW by the
laboratory partners.
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2.0 DATA GENERATION AND ACQUISITION
2.1 Sampling Design
All sampling will follow the Sample Procedure (Appendix A).If a Sample Procedure is updated or
revised,the updated or revised sample procedure will be used for the subsequent sampling event(s).
DDW will document any revisions or updates or both to the Sample Procedure in an amendment to the
QAPP.
Before conducting sampling,the PWS will create a sampling plan and sampling map.These will be
reviewed and approved by the PFP manager.See section 1.9.2.1.
2.2 Sampling Methods
All chemical data,sampling methods,field data,and data analysis methods and procedures shall adhere
to those specified in the Sample Procedure (See Appendix A),U.S.EPA Method 537.1 and 533 (US
EPA,2018b).
2.3 Sample Handling and Custody
Sample handling shall be consistent with the Sample Procedure (See Appendix A).
The PWS or DDW field technician,depending on who is doing the sampling,is responsible for the
custody of the samples from when they have been collected until they have been shipped to the
laboratories.(Note:As few people as possible will handle the samples to ensure sample custody.)The
PWS or DDW field technician must complete the COC form in the field.
Once at the laboratory,laboratory personnel are responsible for the care and custody of samples.
One has custody of a sample if:
-The sample is in the sampler’s physical possession,
-The sample has been in the sampler’s physical possession and is within sight of the sampler,
-The sample is in a secure/designated area,and/or
-The sample has been in the sampler’s possession and has been locked up
2.4 Analytical Methods
2.4.1 Field Measurement and Analyses Methods
No field measurements or analyses are anticipated for this project.Analyses will be conducted by
certified laboratories off-site.
2.4.2 Laboratory Analyses Methods (Off-Site)
The laboratory must use an EPA approved method for the analysis of PFAS in drinking water.See Table
A for approved methods.
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2.5 Laboratory Analysis Quality Control
Quality control samples will match those required in the U.S.EPA Method 533,U.S.EPA Method 537
modified for surface water,and U.S.EPA Method 537.1.Field instruments shall be calibrated daily,
using manufacturer guidelines and requirements.
The laboratory analysis quality control is the responsibility of the personnel and QA/QC department of
the laboratory partner.
2.6 Instrument/Equipment Testing,Inspection,and Maintenance
2.6.1 Field Instruments/Equipment
No field instruments or equipment are anticipated for this project.
2.6.2 Laboratory Analysis Instruments/Equipment (Off-Site)
Inspection and maintenance of laboratory equipment is the responsibility of the laboratories.All
laboratory equipment will be tested,calibrated,and maintained in accordance with existing SOPs
approved by the laboratories.
2.7 Instrument/Equipment Testing and Calibration,Inspection,and Maintenance
All procedures shall adhere to U.S.EPA Method 537.1,U.S.EPA Method 533,US.EPA Method 537
modified for surface water and manufacturer’s calibration,inspection and maintenance
recommendations.Laboratory partners will be responsible for the analytical procedures.
2.8 Inspection/Acceptance Requirements for Supplies and Consumables
2.8.1 Field Sampling Supplies and Consumables
The PFP Manager will inspect the sample bottles received from the laboratory to ensure that the correct
number and volume of bottles were supplied.Sampling bottles are unpreserved,250 mL HDPE or
Polypropylene bottles wide-mouth plastic bottles.The PFP Manager will inspect bottles for cracks,
dents,debris,or other damage.The PFP Manager will add labels to the sample bottles that can capture
the following required information:
-Sample Identification (Source ID or POE ID)
-Sample Time
-Sample Date
-PWS Number
-Sample Type -Field Reagent Blank (FRB)or Drinking Water
-Sample Number (e.g.,Sample 1 out of 2)
See Sampling Procedure (Appendix A)for label examples.
The PFP Manager will ensure that COCs provided by the laboratory can capture the following required
information:
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-Sample Identification (Source ID or POE ID)
-Sample Time
-Sample Date
-Sample Type (FRB or Drinking Water)
-Number of Samples for each Sample ID (including duplicates)
-PWS Number
-Sample collector name,contact information,signature
-Collection data and time
-Submission date and time
2.8.2 Laboratory Analyses (Off-Site)Supplies and Consumables
The laboratories’requirements for supplies and consumables are the responsibility of the Laboratory
Partner.This information is typically included in QA Manual(s)and/or SOPs.
2.9 Data Acquisition Requirements (Non-Direct Measurements)
PWSs may choose to use pre-existing facility maps to create sampling maps.No guarantee is made
regarding the accuracy or availability of information obtained through non-direct measurements.
2.10 Data Management
All laboratory data collected by the PFP will be maintained in the SDWIS electronic database.
Laboratories will send results to DDW via CMDP and email.DDW will upload results to WaterLink.
DDW will send results to PWSs.The contract laboratory will be providing electronic reports in both
PDF and Excel format,including a complete case narrative for each sample set within 14 days of
receiving the samples.The DDW Database/QA Manager will be responsible for assisting the PFP
Manager with laboratory data review,management,and approval.
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3.0 ASSESSMENT AND OVERSIGHT
This section describes how activities will be checked to ensure that they are completed correctly and
according to procedures outlined in this QA Project Plan.
3.1 Assessments/Oversight and Response Actions
The PFP Manager will assess any problem that arises in the field reported by DDW field technicians and
public water systems.If necessary,modifications to technical procedures may be considered.Any
changes in technical procedures will be reported by DDW field technicians or PWS to the PFP Manager
and evaluated to determine if there will be any impact on results or findings.
Laboratory personnel will perform self-audits and institute corrective actions in accordance with their
respective written policies and procedures.
3.2 Reports to Management
The PFP Manager will provide biweekly project updates to the Monitoring and Standards Manager,
and/or Assistant Director/Division Director.At a minimum,the PFP Manager will provide a verbal
report on:
-The number of PWSs enrolled in each step of the program
-The total number of samples with results completed
-Program implementation successes and challenges
-Other issues,as deemed necessary by the PFP Manager
Additional less formal internal reports may take place throughout the project.
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4.0 DATA REVIEW AND USABILITY
This section describes the criteria and procedures for reviewing and interpreting the project’s data.
4.1 Data Review,Verification,and Validation Requirements
Setting data review,verification,and validation requirements helps ensure objective and consistent
evaluation of project data.For the current project,such requirements have been defined for information
gathered and documented as part of field sampling activities,as well as for data generated by the off-site
laboratories.
4.1.1 Field Sampling Data
Any information collected or generated during sample collection is considered field data.This includes
sampling plans,sampling maps,photographs,chain of custody forms,and any other documented
information created during field sampling.
Following field sampling,the PFP Manager will conduct a technical review of the field data to ensure
that all information is complete and was collected in accordance with the Sampling Procedure SOPs
(Appendix A).
4.1.2 Laboratory Data
Laboratory Partners are responsible for their own internal data review and verification before submitting
the associated data results package to PWSs and DDW.
If the laboratories “flag”any sample results based on poor or dubious data quality,the PFP Manager will
coordinate resampling of that sample with the PWSs and DDW field technicians.The PFP Manager will
also evaluate whether flagged data could be traced back to incorrect field sampling techniques.The PFP
Manager will have the authority to suggest new strategies and techniques to PWSs and DDW field
technicians in order to improve sample collection.Any changes will be incorporated into the Sampling
Protocol (Appendix A)and this QAPP,as necessary.
4.2 Verification and Validation Methods
Defining the data verification and validation methods help to ensure that project data are evaluated in an
objective and consistent manner.
4.2.1 Field Data
The PFP Manager will review field data in accordance with the discussion provided in section 4.1.1.
4.2.2 Laboratory Data
Data review of all laboratory generated data is performed by the laboratories’QA Managers.The QA
Manager is responsible for ensuring that all data generated are correct and of known and documented
quality.Once the review is completed,the QA Manager will sign and date the appropriate QA/QC
checklist according to the laboratories’SOP utilized for the analysis for PFAS in the drinking water
samples.
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4.3 Reconciliation with User Requirements
The purpose of the PFP is to assess the presence of PFAS in drinking water at the drinking water sources
and at the POE of PWSs.Data collected must fulfill the requirements of this QAPP to be useful for the
overall program.This section describes the steps to be taken to ensure data usability (after all the data
have been assembled,reviewed,verified,and validated)prior to providing any remediation suggestions.
Once all the data from the field and laboratory have been evaluated (as described in Sections 4.1
and 4.2),the PFP Manager will make an overall assessment concerning the final usability of the data in
meeting the project’s needs.The initial steps of this assessment will include,but not necessarily be
limited to:
-Review of deviations from the QAPP or associated SOPs
-Review for completeness of Electronic Data Deliverable (EDD)
-Evaluation of result accuracy given known context (does the data make sense or are their
unexpected outliers)
-Review of external factors,such as cross contamination
-Review for any laboratory QC indicators
After thorough review of the above,the PFP Manager will review the results to see how they compare to
the program’s action level.Suggestions will follow the “…if…then…”statements included in Section
1.7.2.
Additionally,the PFP Manager,the Water Treatment Specialist and the Monitoring and Standards
Section Manager will regularly assess the effectiveness of the sampling program and data collection.
Sampling SOPs,training,and assessments will be modified as needed to reflect the changing needs and
project objectives of the PFP.This QAPP will be revised,or amended,or both accordingly.
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Title:QAPP for Utah’s PFAS Project
Revision Number:2.1RevisionDate:January 2024
FIGURES:
Figure 1-1.Organization Chart
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Title:QAPP for Utah’s PFAS Project
Revision Number:2.1RevisionDate:January 2024
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Title:QAPP for Utah’s PFAS Project
Revision Number:2.1RevisionDate:January 2024
TABLES:
Table A:Contaminants,Minimum Reporting Levels,and Analytical Methods
Contaminant
Chemical Abstract Service
Registry Number (CASRN)
Minimum Reporting
Level (ppt)Analytical Methods
11-chloroeicosafluoro-3-oxaundecane-1-sulfonic acid (11Cl-PF3OUdS)763051-92-9 2 EPA Method 533
9-chlorohexadecafluoro-3-oxanonane-1-sulfonic acid (9Cl-PF3ONS)756426-58-1 2 EPA Method 533
4,8-dioxa-3H-perfluorononanoic acid (ADONA)919005-14-4 2 EPA Method 533
hexafluoropropylene oxide dimer acid (HFPO DA)13252-13-6 2 EPA Method 533
nonafluoro-3,6-dioxaheptanoic acid (NFDHA)151772-58-6 2 EPA Method 533
perfluorobutanoic acid (PFBA)375-22-4 2 EPA Method 533
perfluorobutanesulfonic acid (PFBS)375-73-5 2 EPA Method 533
1H,1H,2H,2H-perfluorodecane sulfonicacid (8:2FTS)39108-34-4 2 EPA Method 533
perfluorodecanoic acid (PFDA)335-76-2 2 EPA Method 533
perfluorododecanoic acid (PFDoA)307-55-1 2 EPA Method 533
perfluoro(2-ethoxyethane)sulfonic acid(PFEESA)113507-82-7 2 EPA Method 533
perfluoroheptanesulfonic acid (PFHpS)375-92-8 2 EPA Method 533
perfluoroheptanoic acid (PFHpA)375-85-9 4 EPA Method 533
1H,1H,2H,2H-perfluorohexane sulfonicacid (4:2FTS)757124-72-4 2 EPA Method 533
perfluorohexanesulfonic acid (PFHxS)355-46-4 2 EPA Method 533
perfluorohexanoic acid (PFHxA)307-24-4 2 EPA Method 533
perfluoro-3-methoxypropanoic acid (PFMPA)377-73-1 2 EPA Method 533
perfluoro-4-methoxybutanoicacid (PFMBA)863090-89-5 2 EPA Method 533
perfluorononanoicacid (PFNA)375-95-1 2 EPA Method 533
1H,1H,2H,2H-perfluorooctane sulfonic acid (6:2FTS)27619-97-2 2 EPA Method 533
perfluorooctanesulfonic acid (PFOS)1763-23-1 2 EPA Method 533
perfluorooctanoic acid (PFOA)335-67-1 2 EPA Method 533
perfluoropentanoic acid (PFPeA)2706-90-3 2 EPA Method 533
perfluoropentanesulfonic acid (PFPeS)2706-91-4 2 EPA Method 533
perfluoroundecanoic acid (PFUnA)2058-94-8 2 EPA Method 533
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Title:QAPP for Utah’s PFAS Project
Revision Number:2.1RevisionDate:January 2024
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Title:QAPP for Utah’s PFAS Project
Revision Number:2.1RevisionDate:January 2024
Table B:U.S.EPA PFAS Interim HALs and Proposed MCLs
PFAS EPA Interim HALs
(ppt)
EPA Proposed
MCLs (ppt)
PFOS 0.02 4
PFOA 0.004 4
PFBS 2000
Hazard Index (HI)
≤1
GenX 10
PFNA n/a
PFHxS n/a
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Title:QAPP for Utah’s PFAS Project
Revision Number:2.1RevisionDate:January 2024
REFERENCES
Utah Department of Environmental Quality.(2017).Quality Management Plan (Revised
December 2017).Utah Department of Environmental Quality.Retrieved from
UDEQ-Quality-Management-Plan.pdf
Utah Department of Environmental Quality.(n.d.).Strategic Action Plan.Utah Department of
Environmental Quality.Retrieved from
https://documents.deq.utah.gov/admin/strategic-planning/
Utah Department of Environmental Quality.(2020).Reconnaissance Plan for Per and
Polyfluoroalkyl Substances (PFAS)in Utah.Utah Department of Environmental Quality,April
2020.Retrieved from:
https://documents.deq.utah.gov/water-quality/standards-technical-services/DWQ-2021-006579.p
df
Rosenblum,L.,&Wendelken,S.C.(2019).Method 533:Determination of Per-and
Polyfluoroalkyl Substances in Drinking Water by Isotope Dilution Anion Exchange Solid Phase
Extraction and Liquid Chromatography/Tandem Mass Spectrometry.(EPA Document No.
815-B-19-020).Environmental Protection Agency,December 2019.Retrieved from
https://www.epa.gov/dwanalyticalmethods/method-533-determination-and-polyfluoroalkyl-subst
ances-drinking-water-isotope
Shoemaker,J.,AND Dan Tettenhorst.(2018).Method 537.1:Determination of Selected Per-and
Polyfluorinated Alkyl Substances in Drinking Water by Solid Phase Extraction and Liquid
Chromatography/Tandem Mass Spectrometry (LC/MS/MS).(EPA Document No.600/R-18/352)
U.S.Environmental Protection Agency,Office of Research and Development,National Center
for Environmental Assessment,Washington,DC,2018.
https://cfpub.epa.gov/si/si_public_record_Report.cfm?dirEntryId=343042&Lab=NERL
Environmental Protection Agency.(2023).Per-and Polyfluoroalkyl Substances (PFAS).U.S.
Environmental Protection Agency.September 22,2023.Retrieved from
https://www.epa.gov/sdwa/and-polyfluoroalkyl-substances-pfas
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Title:QAPP for Utah’s PFAS Project
Revision Number:2.1RevisionDate:January 2024
APPENDICES
Appendix A:Sampling Procedure
Utah Division of Drinking Water
PFAS
Sampling Procedure
Revision No.1.0
Effective 2023
Utah Division of Drinking Water
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City,Utah 84116
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Title:QAPP for Utah’s PFAS Project
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Planning for the Sampling Event:
A.Minimize Potential Background Contamination
Due to the ubiquitous nature of PFAS,there is a higher than usual potential for sample contamination.To
minimize this potential,careful preparation for this sampling event is strongly recommended.The clothing worn,
personal care products used,and objects brought to the sampling site should be considered as follows:
●Clothes recommended NOT to be worn includes:
○Tyvek suits
○Flame resistant clothing (including shoes,hats,bags,gloves,headsets or accessories)
○Water resistant,stain resistant or water repellant clothing including boots/shoes,hats,bags,gloves
or accessories
○Rain gear made from fluoropolymers such as Gore-Tex,Tyvek,or fabric with water resistant
coating (breathable waterproof)
○Clothing that had been washed with fabric softeners or dried with anti-static sheets
NOTE:On the day of sampling it is recommended to wear clothing that has been washed several times without
fabric softener.
●Avoid use of the Following Personal Care Products Prior To or During the Sampling Event:
○Moisturizers and Creams
○Cosmetic Products (Including Nail Polish)
○Dental Floss
○Shaving Cream
○Sunscreen
○Insect Repellent
○Sanitizer (PFAS-free sanitizer is allowed)
NOTE:The use of such products should be avoided or minimized on the day of sampling,and
24 hours prior to sampling
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●Do not Bring the Following to the Sampling Site:
○Fast food (due to packaging),packaged food,pizza boxes and any food such as
baked goods or sandwiches wrapped in grease-proof paper or bags
○Aluminum foil
○Adhesives (including Post-It notes and Scotch tape)
○Plumber sealant tape (thread tape)and plumbing paste
○Materials containing fluoropolymers such as polytetrafluoroethylene (PTFE or
Teflon®),Ethylene-tetrafluoroethylene (ETFE or Tefzel®),Fluorinated ethylene
propylene (FEP or Hostaflon®FEP,and may also include Neoflon®FEP)
○Waterproof paper or notebooks
○Permanent markers (no removable ink ballpoint pens;no gel pens)
○Plastic clipboards
○Glass bottles should not be used for sampling or to transfer sampling water to
sample bottles (PFAS have been found to adsorb to glass,especially when the
sample is in contact with the glass for a long period of time)
B.Quality Control Field Sampling Types
Due to the prevalence of PFAS in a wide range of materials,there may be a greater likelihood
for cross-contamination during sampling,transport,and storage of samples.As such,it is
required to collect field quality control samples (Field Reagent Blanks)to evaluate if
cross-contamination has occurred.These special quality control sample techniques must be
discussed with the contract laboratory to ensure proper sample containers and materials are on
hand when sampling begins in the field.
●Field Samples (Required)
The field sample is the sample collected from an ENTRY POINT to the
distribution system or a source of a public water system supply.
●Field Reagent Blank (Required)
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A field reagent blank (FRB)is analyzed to assess the potential for PFAS
cross-contamination being introduced during the sample collection/handling
process.The FRB consists of a sample bottle filled at the sample site using
PFAS-free water provided by the contracted laboratory.The FRB is treated as a
sample in all respects,including shipment to the sampling site,exposure to
sampling site conditions,storage,resample preservation,and all analytical
procedures.The FRB must be collected at each sample site and stored in the same
resealable bag and cooler used to store and transport field samples.The contracted
laboratory will provide the FRB sample bottle,the PFAS-free water,and the
preservative.
1.If a PFAS analyte for which there is a proposed or finalized MCL is found
in that sampling site’s sample at or above the laboratory’s method detection
level (MDL),the associated FRB prepared at the sampling site must be
analyzed.
2.If a PFAS analyte for which there is a proposed or finalized MCL is found
in that sampling site’s sample at or above the Method Reporting Limit
(MRL),then this sample site will be resampled and the FRB will be
analyzed.
3.If the method analyte(s)found in the sampling site’s sample is present in
the FRB at a concentration greater than 1/3 the Minimum Reporting Level
(MRL),then all samples collected with that FRB are invalid and must be
recollected and reanalyzed.
4.If a PFAS analyte for which there is not a proposed or finalized MCL is
found in that sampling site’s sample above 15 parts per trillion (ppt),the
associated FRB prepared at the sampling site will be analyzed.
The contracted laboratory will notify the Utah Division of Drinking Water (DDW)
PFAS Project Manager when this occurs.Sample collectors will then schedule a
resample of the Sampling Site should this situation occur.
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●Field Duplicate (Required)
Duplicate samples shall be collected by filling a separate container following the
collection of the primary sample and treated exactly the same throughout field and
laboratory procedures.Field duplicates measure the precision associated with
sample collection,preservation,and storage,as well as
laboratory procedures.
●Temperature Blank (Required)-DO NOT OPEN
The temperature blank is in a sample container that is filled with water and
transported in each sampling shipment of collected samples to determine the
temperature of other samples in the shipment on arrival at a laboratory.The
temperature blank bottle should be left in the cooler and shipped back to the
contract laboratory.It is used to indicate the temperature of the sampling bottles.
Preparing for the Sampling Event:
A.Needing ‘in-person’technical assistance to sample:
1.After a request for sampling is received from a PWS,the PFAS Project (PFP)Manager
will send the sampling plan template to the PWS.The PWS will fill and send the
sampling plan to the Field Technician or the PFP Manager.The sampling plan will
contain all pertinent PWS data (PWS name,facility ID number,etc)to ensure that the
correct number of bottles and supplies can be ordered from the contracted laboratory.
2.The Field Technician will contact the PWS to make an appointment to collect samples.
The date of the appointment must be at least two weeks after the Field Technician
contacts the PWS to ensure enough time for ordering and obtaining the required bottles
and supplies for sampling.
3.The PFP Manager is responsible for notifying the contracted laboratory immediately after
the confirmed PWS sampling date to order necessary sample kits.This is done to provide
the contracted laboratory with the time necessary for the preparation of the sampling kits.
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4.Once sample bottles and materials are received from the contracted laboratory,the PFP
Manager or the Field Technician will verify the quantity of bottles/sampling material and
add the pre-filled sampling labels to the sample bottles and prepare the pre-filled
Chain-of-Custody (COC)forms.
B.Not needing in-person technical assistance to sample:
1.After a request for sampling is received,the PFP Manager will send the sampling plan
template to the PWS.The PWS will fill and send the sampling plan to the Field
Technician or the PFP Manager.The sampling plan will contain all pertinent PWS data
(PWS name,facility ID number,etc)to ensure that the correct number of bottles and
supplies can be ordered from the laboratory.
2.The PFP Manager is responsible for ordering the necessary sample kits from the
contracted laboratory.
3.Once sample bottles and materials are received from the contracted laboratory,the PFP
Manager or the Field Technician will verify the quantity of bottles/sampling material and
add the pre-filled sampling labels to the sample bottles and prepare the pre-filled COC
forms.
4.Sampling kits are then packaged in the coolers.Sampling instructions and shipping labels
to the contracted laboratory are added to the coolers.Packaged coolers are sent to the
PWS.
What is Included in the Sampling Kit?
●For each sample,two labeled 250 mL capped sampling bottles with preservative
(Provided by the Contracted Laboratory/Labeled by DDW)
●For each sample,two labeled 250 mL capped FRB bottles with preservative (Provided by
the Contracted Laboratory/Labeled by DDW)
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●Pre-filled Chain of Custody Forms (Provided by DDW)
●Shipping Instruction and pre-paid shipping label(s)(Provided by DDW)
●Sampling Instructions (Provided by DDW)
●For each sample,two bottles of PFAS Free Water (Provided by the Contracted
Laboratory)
●Packing &Shipping Instructions (Provided by Contracted Laboratory)
●Cooler for shipping samples back to the Contracted Laboratory (Provided by the
Contracted Laboratory)
●Pairs of powderless nitrile gloves for each sampling point (Provided by the Contracted
Laboratory)
●Plastic Ziplock-style Bags (Provided by the Contracted Laboratory)
●TEMP Blank Bottles -Do Not Open this Bottle (Provided by the Contracted Laboratory)
●Temperature Controlled Sticker (Provided by the Contracted Laboratory)
●Absorbent Pad (Provided by the Contracted Laboratory)
●Custody Seal (Provided by the Contracted Laboratory)
●Plastic Liner (Provided by the Contracted Laboratory)
The Sampling Event
The samples must be collected and shipped Monday-Wednesday to ensure that
the contract lab receives them within proper holding temperature.
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A.Information Relevant to the Day of Sampling Event
●When transporting samples,do NOT place samples/bottles directly on vehicle
upholstery,office upholstery,or floor rugs since they most likely have been treated for
stain,fire and/or water resistance.
●Field sampling occurring during extreme weather (e.g.,rainfall,snowfall,or extreme
heat)shall be conducted while wearing the appropriate clothing that will not pose a
risk for cross-contamination yet will ensure the safety of the field personnel.
●Avoid sampling during rain if possible (if necessary,polyvinyl chloride,polyurethane,
polyethylene or rubber rain gear can be worn).
●Keep caps on all sample bottles until time to collect sample or prepare FRBs or field
duplicates.Do NOT mix up caps and bottles.
●DO NOT confuse the bottles to be used for the FRBs with the bottles to be used for the
sampling points.
●Use a fresh/new pair of powderless nitrile gloves at each sampling site.
●Ensure that the cooler interior is clean.
B.Sample Collection Procedure:
Fill the Sample Bottles and Duplicates:
1.Ensure that the sample bottles are labeled appropriately.Check that the bottle
labels have the correct PWS name,Facility ID number or Entry Point number and
match the COC form.You will have two sample bottles for each sampling
location.The labels will have “1 of 2”and “2 of 2”on them.
2.Wash hands with PFAS-free soap.Use non-PFAS treated paper towels or a
PFAS-free hand towel.
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3.Remove aerators or screens on sampling tap if present.Reduce the flow to a slow
stream to reduce air entrapment and prevent overfilling the bottle.
4.Put on a clean pair of powderless nitrile gloves,taking extra caution not to touch
any surface prior to sample collection.
5.Collect the samples by filling the two sample bottles to the neck.
DO NOT:
●Overfill since that will cause loss of the preservative.
●Place the bottle cap on any surface when collecting the sample and avoid all
contact with the inside of the sample bottle or cap.
6.Cap the bottle and invert three times to dissolve the preservative.DO NOT OPEN.
7.Record the date and time of the sample collection on the sampling bottle,labels
and the COC.Be sure that the information on the COC form matches the
information on the sample bottle label.
Fill the FRB Bottles:
8.The FRB bottles should have a label that says “Field Regent Blank (FRB)”.
9.Ensure that the FRB bottles are labeled correctly.Check that the bottle labels have
the correct PWS name,Facility ID number or Entry Point number and match the
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COC form.You will have two FRB bottles for each sampling location.The labels
will have “1 of 2”and “2 of 2”on them.
10.At the same location the sample bottles were filled and right after filling the
sample bottles,fill the FRB bottles by opening the bottles labeled “PFAS Free
Water”and pouring them into the empty FRB bottles.If there are multiple FRB
bottles,make sure to match the label with the same sampling location.
11.As the label says,don’t overfill the bottle or rinse out the preservative.Fill in the
date and time the sample was taken on the label.
12.Cap the bottle and invert three times to dissolve the preservative.DO NOT OPEN.
13.DO NOT USE any remaining laboratory PFAS Free water.Discard excess PFAS
Free water.
14.The empty PFAS Free water bottle shall not be shipped with the samples back to
the laboratory and may be discarded or recycled.
15.On the COC form,record the date and time that the FRB was prepared for the
sampling location.
16.Record field site observations in the PFAS Field Sheet such as percentages of
flows for different sources for that sampling site if applicable.
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C.Storage of Samples after Collection and before Shipping:
●Samples must not exceed 50°F (10°C)and must be shipped immediately or soon
after as the bottles need to be received by the laboratory within 2 days of
collection.
●The samples that are significantly above 50°F (10°C)at the time of collection and
samples that will not be shipped immediately,will need to be iced or refrigerated
to chill them prior to shipping to the contracted laboratory.Samples should not be
frozen.
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●Samples must be at or below 50°F (10°C)when received at the contracted
laboratory.
●The goal is for the contracted laboratory to receive samples within 48 hours of
sample collection.
D.Sample Shipping:
Prepare for Packing:
1.Make sure the pre-populated Chain of Custody form’s highlighted areas are
completely filled.Take a picture or scan the completed form and send it to PFAS
Program Manager,Sarah Romero,at [e-mail] place it in a
ziplock bag and return with the cooler.
2.Insert the two sampling bottles into one ziplock bag and the two FRB bottles into
one ziplock bag.Remove the air out of the bag and completely seal it.
Pack the Cooler:
1.Insert absorbent pad.
2.Insert bubble wrap.
3.Add plastic liner and add all contents into this liner:
a.Ziplock-style bags with Sampling Bottles and FRB Bottles
b.TEMP Blank Bottle
c.Place bubble wrap between bottles
4.Fill the liner with loose ice cubes.
Secure Cooler:
1.Twist or tie plastic liner closed
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Title:QAPP for Utah’s PFAS Project
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2.Add a layer of bubble wrap on top.
3.Place the Chain of Custody on top of the bubble wrap in the cooler.
Prepare and Arrange to Ship:
1.After packing and closing the cooler,fill out the custody seal
and place the seal such that the sticker must be broken to open the cooler.Also
place a “Temperature Controlled”sticker on the outside of the cooler.
2.Add the shipping labels provided by DDW on the coolers.(Shipping should be
priority overnight).
3.Close lid and tape shut.
4.Drop off coolers to Fedex or arrange a Fedex pickup at your location.
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Title:QAPP for Utah’s PFAS Project
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Appendix B:Chain of Custody Form
37