TCEQ outlines PFAS monitoring timeline and lab requirements ahead of 2027 initial monitoring

Emily Smith, team leader for the drinking water quality team at the Texas Commission on Environmental Quality, told the Groundwater/Wastewater Advisory Group that federal PFAS maximum contaminant level (MCL) compliance will begin in 2029 and that initial monitoring is due well before that.

"Maximum contaminant level compliance will begin in 2029," Smith said, adding that initial monitoring for regulated PFAS is due April 20, 2027. She described which systems must collect two samples per entry point and which must collect four, and said some previously collected UCMR 5 data can be used if it meets EPA data-quality criteria.

The nut graf: The TCEQ presentation spelled out monitoring frequencies, the numeric trigger levels that determine reduced monitoring, and a near-term requirement that labs analyzing PFAS be certified by EPA or TCEQ for samples collected after June 4, 2024. Water systems and laboratories must act now to ensure historic samples are reprocessed to lower method reporting limits if systems intend to use them for initial monitoring in 2027.

TCEQ listed the five individual PFAS analytes with MCLs in parts per trillion and a new unitless hazard-index approach for mixtures. For many small groundwater community and nontransient noncommunity systems serving 10,000 people or fewer, the initial monitoring requirement is two samples per entry point collected five to seven months apart; larger systems and all surface-water systems generally must collect four samples per entry point collected two to four months apart. Smith said previous UCMR 5 samples are acceptable for initial monitoring if the lab used EPA methods 533 or 537.1 and the sampling was done on or after Jan. 1, 2019.

TCEQ staff emphasized that reduced monitoring at an entry point requires all initial monitoring results to be below trigger levels set at one-half of the MCLs (for example, 2 parts per trillion for PFOA and PFOS; 5 parts per trillion for GenX, PFHxS and PFNA). "EPA's PQLs are currently based on the UCMR 5 MRLs," Smith said, and many labs report only at those higher values; systems that wish to use historic UCMR 5 results will need to work with participating labs to reprocess raw data to the lower trigger levels.

Smith also described how data will be reported to the agency. TCEQ is working on an approach to accept PFAS data into its data systems and said that laboratories will report routine compliance data; for initial monitoring the lab will generally deliver an electronic data deliverable (EDD) to the agency in formats TCEQ specifies during the implementation period. She encouraged systems to coordinate with their laboratories now so the labs can plan for method reprocessing and for certification under EPA/TCEQ programs.

The presentation closed with contact information (pwspfas@tceq.texas.gov) and links to EPA memos and fact sheets, which TCEQ said it will post on its web pages for systems to use when preparing for initial monitoring.

Ending: TCEQ staff urged public water systems to start conversations with laboratories and to inventory prior PFAS sampling carefully: reprocessed UCMR 5 results may be acceptable for initial monitoring, but only if the lab can meet the lower trigger levels and EPA/TCEQ certification requirements.