S MICHIGAN RICK SNYDER DEPARTMENT OF HEALTH AND … · oral RfD for PFOA and PFOS of 20 ng/kg/day....

333 SOUTH GRAND AVENUE • PO BOX 30195 • LANSING, MICHIGAN 48909 www.michigan.gov/mdhhs • 517-373-3740

June 4, 2018 Adam London, MPA, RS, DAAS Health Officer Kent County Health Department 700 Fuller Avenue NE Grand Rapids, Michigan 49503 Re: Recreational contact with PFAS-containing foam on the Rogue River, Rockford, Michigan. Dear Mr. London: The Michigan Department of Health and Human Services (MDHHS) Division of Environmental Health has evaluated per- and polyfluoroalkyl substances (PFAS) analytical data for surface water from and for foam observed on the Rogue River in Rockford, Michigan. Surface water samples from the Rogue River and its tributary Rum Creek were collected in October 2017 and a sample of foam observed on the Rogue River near the Rockford Dam was collected in April 2018. Concentrations of PFAS in foam were high relative to concentrations in surface water. MDHHS considered absorption of PFAS following skin contact with foam as well as swallowing foam, which could occur incidentally during recreational activities (e.g., swimming, playing) in the Rogue River. Available information suggests that, as a class of chemicals, PFAS do not easily enter through the skin, although the extent to which they do cross the skin depends on the chemical’s characteristics, and some PFAS are more readily absorbed than others. Even under worst-case conditions for skin contact, PFAS were not determined to be absorbed at levels that would pose a risk to human health. Incidental ingestion (i.e. swallowing), however, may pose a risk to human health at the concentrations reported in recent foam samples. Gastrointestinal absorption of PFAS is highly efficient and therefore exposure to PFAS from swallowing foam is considered a primary exposure pathway for humans. Dermal contact with, and incidental ingestion of, PFAS-containing water during recreational activities in the Rogue River are not expected to pose a risk to human health. Therefore, MDHHS has reached the following conclusion: Based on the high levels of PFAS found in foam samples, the evidence for health effects associated with the ingestion of PFAS above EPA’s health criterion, and the lack of scientific information fully characterizing exposure to PFAS via foam, MDHHS concluded that swallowing this PFAS-containing river foam may pose a human health risk. Therefore, MDHHS is recommending a public health advisory that precautions be taken to avoid the incidental ingestion of foam during recreational activities (e.g., swimming, kayaking, fishing) on the Rogue River.

NICK LYON DIRECTOR

RICK SNYDER GOVERNOR

STATE OF MICHIGAN DEPARTMENT OF HEALTH AND HUMAN SERVICES

LANSING

http://www.michigan.gov/

This conclusion has the following limitations: 1. Analytical data from future foam sampling events could change MDHHS’s

conclusions and recommendations regarding recreational contact with river foam.

2. Standard, accepted values for some of the properties of PFAS are not yet available or are considered unmeasurable. The availability of new information about the properties of PFAS could alter MDHHS’ conclusions and recommendations.

3. There are other potential exposure pathways of PFAS near the Rogue River, including the consumption of locally-caught non-migratory fish or the drinking of water from wells that have an elevated concentration of PFAS. Avoiding contact with river foam alone may not ensure that all exposure pathways have been eliminated.

Based on the conclusion above, and its limitations, MDHHS recommends the following: 1. A public health advisory should be issued to avoid ingestion of foam during recreational

activities, such as swimming, canoeing/kayaking, and fishing, in water or along the shore of the Rogue River.

2. It is not necessary to issue advisories against contact with or ingestion of river water; nor is it necessary to issue advisories against skin contact with foam.

3. MDEQ should continue to monitor the Rogue River for foam, collect and analyze foam samples when they are available, and collaborate with MDHHS on the development of foam collection and risk assessment protocols for PFAS-containing foam events.

MDHHS has issued Eat Safe Fish guidelines for the Rogue River due to a variety of chemicals, including perfluorooctane sulfonate (PFOS, a common PFAS chemical) and mercury. See michigan.gov/eatsafefish for more information and current advisories. An attachment detailing the evaluation of these data is included. Please let me know if I can be of any further assistance in this matter. Sincerely,

Deborah MacKenzie-Taylor, Manager Toxicology and Response Section Division of Environmental Health Michigan Department of Health and Human Services CC: MDEQ MDNR City of Rockford

Technical Review Evaluating Recreational Exposure to Per- and Polyfluoroalkyl Substances (PFAS) in Foam on the Rogue River, Rockford (Kent County), Michigan Prepared by William Farrell, Toxicologist, Toxicology and Response Section, Michigan

Department of Health and Human Services, Division of Environmental Health June 1, 2018

Per- and polyfluoroalkyl substances (PFAS), although manmade, are found ubiquitously in nature and are present in nearly all marine and terrestrial animals, including humans. PFAS can readily migrate into ground water and contaminate surface waters. An unusual foam has appeared on water bodies in Michigan located near known sources of PFAS, notably Air Force/Air National Guard bases where AFFF was used regularly, such as Van Etten Lake in Iosco County, MI on which the former Wurtsmith Air Force Base is located. This type of foam has also been observed in the Rogue River near the Rockford Dam (see Attachment 1). The Rockford Dam is located near the former Wolverine Worldwide Tannery, a known source for PFAS contamination to groundwater. A sample of this foam was taken from the surface of the Rogue River downstream of the Rockford Dam on April 6, 2018 and tested for the presence of PFAS. The April 2018 sample was collected by AECOM, a contractor to the Michigan Department of Environmental Quality (MDEQ), and submitted to Vista Laboratories for analysis for PFAS. The concentrations of PFOA+PFOS and total PFAS detected in the foam sample are shown in Table 1. Additionally, in 2017, a total of seven surface water samples were collected from the Rogue River and one surface water sample was collected from Rum Creek, a tributary to the Rogue River. The maximum concentrations of PFOA+PFOS and maximum total PFAS concentration for the surface water samples are provided in Table 1. Both the foam and surface water samples were analyzed for numerous individual PFAS (foam – 24 PFAS analytes, surface water – 23 PFAS analytes); however, MDHHS evaluated the two PFAS – perfluorooctanoic acid (PFOA) and PFOS – for which the U.S. Environmental Protection Agency (EPA) has established an oral (i.e. ingestion) Reference Dose (RfD) and for which groundwater-derived drinking water limits have been established in Michigan. A Reference Dose is the amount of a chemical per body weight that is estimated not to cause harm over a lifetime of exposure, even in sensitive groups such as children and fetuses. The EPA has established an oral RfD for PFOA and PFOS of 20 ng/kg/day. The drinking water limits were set to be protective of human health both for short-term (i.e., weeks to months) scenarios during pregnancy and lactation, as well as to lifetime-exposure scenarios. The EPA has established a Lifetime Health Advisory for PFOA and PFOS in drinking water at a concentration of 70 ppt (ng/L). Exposure to contaminated surface water foam is a novel problem and the risk assessment for this scenario is currently under development and may evolve as more data become available. Dermal (skin) contact with foam and incidental ingestion of foam, which often occurs during recreational activities, were considered. Inhalation was not considered to be a realistic route of exposure for PFAS in a foam medium and therefore was not considered in this health assessment. Dermal Exposure. Neither the EPA nor any other agency has established a reference dose or exposure concentration limit for foam specifically or for dermal contact with PFAS substances generally. All health advisories to-date are for the consumption of PFAS via contaminated water sources, and

the Agency for Toxic Substances and Disease Registry (ATSDR) has stated1 that “studies have shown that only a small amount of PFAS can get into your body through your skin. Therefore, showering and bathing in water containing PFAS should not increase exposure. Washing dishes in water containing PFAS should not increase exposure.” Similar recommendations have been expressed in numerous other public health statements2,3,4,5,6,7. While these statements are not made about contact with surface water foam specifically, they do address dermal exposure to PFAS, for which the mechanisms of absorption are expected to be similar regardless of the matrix within which the PFAS is located (i.e. skin contact with water is considered to be comparable to skin contact with foam). Some information traditionally used to evaluate dermal environmental exposures is not yet available for many PFAS, such as permeability coefficients (Kp), octanol/water partition coefficients (Ko/w) and precise degrees of ionization (for environmental samples). Therefore, MDHHS has used values for PFOA, only, that have been derived in the experimental literature. PFOA, although not the only or primary8 PFAS found in Rogue River foam, is thought to have a high capacity for skin permeability (higher than PFOS, for example) and therefore should capture a reasonable worst-case scenario of skin contact with PFAS-containing surface water foam. When considering the concentration to evaluate for the health assessment, MDHHS used the combined PFOS and PFOA concentration from the April 2018 sampling event, as those are the two individual PFAS for which health-based screening levels currently exist. The reported concentration of combined PFOA and PFOS from the Rogue River foam sample was 261,255 ng/L. This total concentration corresponds to 261,000 ng/L PFOS and 255 ng/L PFOA. The EPA Dermal Exposure Assessment Guide9 describes an equation for quantifying an absorbed dose per exposure event (Equation 1) and, using that, for quantifying a total dermal absorbed dose (Equation 2): Equation 1. 𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 = 𝐾𝐾𝐾𝐾 ∗ 𝐶𝐶𝐶𝐶 ∗ 𝑇𝑇𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 Where,

DAevent= absorbed dose per event in mg/cm2/event Kp= permeability in cm/hr Cw= concentration in foam in mg/cm3 Tevent= hours of dermal contact with foam in hr/event

1 https://www.atsdr.cdc.gov/pfas/pfas-exposure.html , webpage updated Jan 10, 2018 2 http://www.secnav.navy.mil/eie/Documents/WhatToDoIfYouHaveBeenExposed.pdf 3http://dhss.alaska.gov/dph/Epi/eph/Documents/PFCs/Moose%20Creek_PFAS%20Fact%20Sheet_Dec%201%202016.pdf 4 https://www.mass.gov/files/documents/2016/07/sy/pfas-drink-wtr-fact-sheet.pdf 5 https://www.health.ny.gov/environmental/investigations/drinkingwaterresponse/docs/atsdr_pfas_factsheet.pdf 6 http://www.health.state.mn.us/divs/eh/hazardous/topics/pfcshealth.pdf 7 http://www.health.ri.gov/water/about/pfas/ 8 PFOS was found in the foam at a much higher concentration (261,000 ng/L) relative to PFOA (255 ng/L). 9 https://cfpub.epa.gov/ncea/risk/recordisplay.cfm?deid=183584

https://www.atsdr.cdc.gov/pfas/pfas-exposure.html%20webpage%20updated%20Jan%2010

http://www.secnav.navy.mil/eie/Documents/WhatToDoIfYouHaveBeenExposed.pdf

http://dhss.alaska.gov/dph/Epi/eph/Documents/PFCs/Moose%20Creek_PFAS%20Fact%20Sheet_Dec%201%202016.pdf

http://dhss.alaska.gov/dph/Epi/eph/Documents/PFCs/Moose%20Creek_PFAS%20Fact%20Sheet_Dec%201%202016.pdf

https://www.mass.gov/files/documents/2016/07/sy/pfas-drink-wtr-fact-sheet.pdf

https://www.health.ny.gov/environmental/investigations/drinkingwaterresponse/docs/atsdr_pfas_factsheet.pdf

http://www.health.state.mn.us/divs/eh/hazardous/topics/pfcshealth.pdf

http://www.health.ri.gov/water/about/pfas/

https://cfpub.epa.gov/ncea/risk/recordisplay.cfm?deid=183584

Equation 2.

𝐷𝐷𝐷𝐷𝐷𝐷 =𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 ∗ 𝐸𝐸𝐸𝐸 ∗ 𝐸𝐸𝐷𝐷 ∗ 𝐸𝐸𝐸𝐸 ∗ 𝑆𝑆𝐷𝐷

𝐵𝐵𝐵𝐵 ∗ 𝐷𝐷𝑇𝑇

Where,

DAD= dermal absorbed dose in ng/kg/day EV= events/day ED= exposure duration in years EF= exposure frequency in days/year SA= skin surface area in cm2 BW= body weight in kg AT= averaging time in days

Equation 2 yields the expected dose that is absorbed following skin contact with foam. This equation includes factors that capture the size (body weight and surface area of the skin) of the person, the length of time they are exposed and the ability for the chemical to effectively penetrate the skin barrier and enter the body. MDHHS considers this exposure scenario to likely over-estimate skin contact with foam, as it assumes the entire child’s body except the head is in contact with foam for the length of the exposure duration and frequency. This is very unlikely to occur because foam floats on the surface of the water or may blow along the shore and in most cases only a portion of the skin would contact the foam. It should also be noted that the concentration used represents the amount of PFOA+PFOS per liter of the liquid portion of the foam (liquid condensate), not per liter of foam itself. MDHHS considered that contact with the foam would likely form a uniform liquid layer on the skin (i.e. that all of the air pockets collapse upon contact), which further represents a possible overestimation. Should the foam matrix remain intact, a factor accounting for the decreased portion of the skin surface area in contact with foam that was actually exposed to PFAS-containing water would be used and would decrease DAD accordingly (by a factor of 31 in this case, see the section on Oral Exposure below for more detail). To further capture a worst-case scenario, MDHHS has considered a young child exposed to this foam for 2 hrs per weekday during the summer months. The following plausible worst-case variables were included using the EPA Exposure Factors Handbook10 to define human factors where applicable:

Dermal permeability (Kp)11. Franko et al., (2012) reports the Kp of PFOA to be 0.00009 cm/hr under conditions most applicable to real-world exposures.

10 https://rais.ornl.gov/documents/EFH_2011.pdf 11The Kp for PFOA is applied here considering the following rationale: The EPA provides tools to estimate the Kp of chemicals, when experimentally-derived values are unknown. However, these calculations require knowledge of other properties of the chemical, such as Kow, which is not known for many PFAS, including PFOS. Further estimates of those properties can be made, and an estimated Kp can be derived from an estimated Kow, but when this is done for PFOA (for which there is an experimentally derived Kp), the estimated Kp and experimentally derived Kp differ by several orders of magnitude. For this reason, until more information is available for these chemicals, MDHHS did not consider estimated Kp values and instead applied the published Kp for PFOA in the present health assessment. This was determined to be appropriate, and protective of human health, based on the following: 1) when Kp estimates were conducted by MDHHS for the most common PFAS analytes (PFOA, PFOS, PFHpA, PFBS, PFBA) using estimated Kow values and molecular weights, PFOA had the highest Kp (i.e. dermal permeability), however, that estimate did yield a higher Kp value than that which was reported in the literature. 2) The physiochemical properties of PFOA

https://rais.ornl.gov/documents/EFH_2011.pdf

Duration of dermal contact (Tevent). The duration per event of dermal contact with foam is assumed to be 2 hours, which is thought to represent the maximal, reasonable time that a young child might be engaging in recreational activities on the river including time spent in the water and playing on the shoreline12. Surface area (SA). A child aged 1-2 years old was considered, with the mean skin surface area of 4,450 cm2(entire body except the head). Body weight (BW). The mean body weight for a child aged <2 years old (male and female average) of 10.2 kg was used. Events per day (EV). One event per day (lasting 2 hours in duration) is assumed to be representative of the worst-case scenario for a young child. Exposure frequency (EF). Rogue River is typically used for recreation only during the summer months. The dermal exposure scenario here assumes a child playing in foam 5 days per week for 12 weeks out of the year. Exposure Duration (ED). An exposure duration equal to 12 weeks was considered for this model scenario; the averaging time (AT) was set to 84 days.

The dermal absorbed dose generated from Equations 1-2 for this scenario was 14.65 ng/kg/day. This dose was compared to the EPA’s reference dose (RfD) for PFOA and PFOS, which is 20 ng/kg/day13. The comparison of the Exposure Dose to the Reference Dose results in a Hazard Quotient (HQ). A HQ that is greater than one indicates that further evaluation of the exposure is needed, while a HQ that is less than one indicates that further evaluation may not be needed. The HQ for dermal contact with the river foam, under the above conditions, was 0.73. MDHHS has concluded that minimal risk of harm to human health exists following skin contact with foam during swimming or other recreational activities. Using the assumptions described above, a young child contacting the PFAS foam while playing in the river for 2 hrs/day, 5 days/week, 12 weeks/year would not be expected to be harmed as a consequence of this exposure. MDHHS believes that by modelling the most vulnerable receptor (i.e. a child) and using worst-case exposure factors, that other receptors (older children and adults) will be protected by the recommendations derived from this analysis. Oral Exposure. The 2011 EPA Exposure Factors Handbook14 includes rates of incidental ingestion of water during swimming. It does not include an analogous estimate for the incidental ingestion of foam, necessitating the use of the incidental water ingestion rate as a best estimate for foam ingestion. However, the concentration of PFOS+PFOA used above reflects the amount of PFAS in just the liquid portion of the foam; based on in-the-field reports from AECOM sampling, 0.5 gallon (1.89L) of foam yielded approximately 0.06 L of liquid, a 31:1 ratio (see Activity Log in Attachment 2). make it more likely to cross the skin barrier compared to other PFAS analytes, which was borne out in the estimate calculations. 12 Because foam can accumulate along the shore, restricting an exposure scenario to only a reasonable swim period was not considered to capture a realistic worst-case scenario for foam exposure. 13 https://www.epa.gov/sites/production/files/2017-12/documents/ffrrofactsheet_contaminants_pfos_pfoa_11-20-17_508_0.pdf 14 https://rais.ornl.gov/documents/EFH_2011.pdf

https://www.epa.gov/sites/production/files/2017-12/documents/ffrrofactsheet_contaminants_pfos_pfoa_11-20-17_508_0.pdf

https://rais.ornl.gov/documents/EFH_2011.pdf

Applying this ratio to the EPA estimate for incidental ingestion of water during swimming (0.049 L per hour, or 0.098 L for 2 hours for a child less than the age of 18), MDHHS considered an ingestion rate of PFAS-containing water via foam to be 0.002 liters (L) per 60 min, or 0.004 L for 2 hours. To calculate an oral (ingested) exposure dose, the concentration of the foam was multiplied by the ingestion rate (the amount swallowed) and divided by body weight:

Equation 3. 𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 = 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝑋𝑋 𝐼𝐼𝐶𝐶𝐼𝐼𝐶𝐶𝐼𝐼𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝑅𝑅𝐶𝐶𝐶𝐶𝐶𝐶

𝐵𝐵𝐶𝐶𝐵𝐵𝐵𝐵 𝑊𝑊𝐶𝐶𝐶𝐶𝐼𝐼ℎ𝐶𝐶

The same exposure scenario as described above, for dermal exposure, was applied here. Therefore, a body weight of 10.2 kg for children younger than 2 years of age, a foam ingestion rate corresponding to a 2-hr exposure and the concentration of PFOA+PFOS reported for the foam sample (261,255 ng/L) were considered. The calculation from Equation 3 results in an estimated PFOA+PFOS exposure dose for incidental ingestion of foam to be 102.45 ng/kg/day. MDHHS then compared the calculated oral exposure dose to the EPA’s RfD of 20 ng/kg/day, to generate a HQ for oral exposure. The HQ for incidental swallowing of river foam, based on the above exposure dose, was5.1. The HQ derived from this calculation is greater than 1 and drives the recommendation by MDHHS that incidental ingestion of foam should be avoided. Using the same exposure scenario described above, MDHHS calculated an oral exposure dose from incidental swallowing of water during recreational activities in the Rogue River. The maximum concentration of PFOA+PFOS for surface water samples (16.8 ng/L – see Table 1) collected from the Rogue River, along with the 2-hour incidental ingestion rate of 0.098 L and 10.2 kg child body weight, were used in Equation 3 to estimate oral exposure to PFAS in the Rogue River. The calculation from Equation 3 results in an estimated PFOA+PFOS exposure dose for incidental ingestion of river water of 0.16 ng/kg/day. Comparing the oral exposure dose to EPA’s RfD of 20 ng/kg/day results in a HQ of 0.008. The resulting HQ is less than 1; therefore, incidental ingestion of Rogue River water during recreational activities is not expected to harm human health. Limitations. Limitations to the dermal exposure model used here reflect the sparsity of relevant physiochemical information on nearly all individual PFAS, as well as a lack of understanding about how mixture exposures can influence the absorption, distribution, metabolism and/or elimination of individual PFAS constituents. Specifically, MDHHS recognizes that additional experimental data could indicate a higher (or lower) dermal permeability of PFOA and/or a reliable Kp for PFOS, in which case the HQs discussed here would need recalculating. There are considerable unknowns at this time about the dermal permeability of PFAS-containing surface water foam, and it is assumed that dermal permeability is dependent on the chemical form of the foam-constituents. Also, it is possible the exposure scenario selected here is not realistic for the Rogue River and might overestimate contact with PFAS-containing river foam. Similarly, the estimated rate for incidental ingestion of foam may not reflect realistic events. The variables used for these factors were based on the best information currently available.

Table 1. Concentrations (nanograms per liter [ng/L]) of PFAS in foam and surface water samples from Rogue River, Rockford (Kent County), Michigan.

Sample Description/Location (Sampler) Sample Date PFOA + PFOS

(ng/L) Total1 Detected2

PFAS (ng/L)

Foam/Rogue River (AECOM) April 13, 2018 261,255 296,584 Surface Water/Rogue River (GZA) Oct. 12, 2017 16.8 28.1

1 A total 24 PFAS analytes were tested in the foam sample and 23 PFAS analytes were tested in the surface water samples. 2Analytes that were not quantified because they were below the detectable limit are not included in the "Total Detected PFAS" column.

ATTACHMENT 1 _________________________________________________________________________ Image 1. Photo of foam at Rogue River on April 6, 2018. Photo taken by AECOM during the sampling event.

Note: This is a shoreline observation that occurred during the sample collection of Rogue River foam.

ATTACHMENT 2 _________________________________________________________________________

GRAND RIVER

ROGUE RIVER

Map Location LegendFoam Sample Location

Prepared: 0 0.50.25 Miles

FOAM SAMPLE LOCATIONSROGUE RIVER

NORTH KENT DISPOSAL AREAKENT COUNTY, MI

G:\GrandRapids\DCS\GIS\ArcMap_GeoDB_Projects\ENV\GIS_Data\GIS\North_Kent\MXDs\180508_RogueRiver_ChildsdaleBridge_FoamSample.mxd5/30/2018

DRAFT

Enclosed are the results for the sample set received at Vista Analytical Laboratory on April 13, 2018. This sample

set was analyzed on a standard turn-around time, under your Project Name 'MDEQ North Kent PFAS'.

Vista Analytical Laboratory is committed to serving you effectively. If you require additional information,

please contact me at 916-673-1520 or by email at [email protected].

Thank you for choosing Vista as part of your analytical support team.

Sincerely,

Martha Maier

Laboratory Director

May 29, 2018

Vista Work Order No. 1800668

Merit Laboratories, Inc.

2680 East Lansing Drive

East Lansing, MI 48823

Dear Ms. Murshak,

Ms. Maya Murshak

Vista Analytical Laboratory certifies that the report herein meets all the requirements set forth by NELAP for those applicable test

methods. Results relate only to the samples as received by the laboratory. This report should not be reproduced except in full without

the written approval of Vista.

Vista Analytical Laboratory 1104 Windfield Way El Dorado Hills, CA 95762 ph: 916-673-1520 fx: 916-673-0106 www.vista-analytical.com

Work Order 1800668 Page 1 of 17

Vista Work Order No. 1800668

Case Narrative

Sample Condition on Receipt:

Two aqueous samples were received in good condition and within the method temperature requirements . The

samples were received and stored securely in accordance with Vista standard operating procedures and EPA

methodology.

Analytical Notes:

PFAS Isotope Dilution Method

Samples "FOAM1804061515JLB" contained particulate and was centrifuged prior to extraction.

The samples were extracted and analyzed for a selected list of PFAS using the PFAS Isotope Dilution Method

(Modified EPA Method 537).

Holding Times

The samples were extracted and analyzed within the method hold times.

Quality Control

The Initial Calibration and Continuing Calibration Verifications met the method acceptance criteria.

A Method Blank and Ongoing Precision and Recovery (OPR) sample were extracted and analyzed with each

preparation batch. No analytes were detected in the Method Blanks above 1/2 the LOQ. The OPR recoveries

were biased high. It was determined that the OPR standard solution had concentrated; this was confirmed by

analyzing an aliquot of the solution. Backup volume was not available for a re-extraction, however, the accuracy

of the sample results were not affected by the OPR QC excursion.

The labeled standard recoveries for all QC and field samples were within the acceptance criteria.


TABLE OF CONTENTS

Case Narrative................................................................................................ 1

Table of Contents........................................................................................... 3

Sample Inventory........................................................................................... 4

Analytical Results.......................................................................................... 5

Qualifiers........................................................................................................ 14

Certifications.................................................................................................. 15

Sample Receipt.............................................................................................. 16


Client

Sample ID

Sample Inventory Report

Vista

Sample ID Sampled Received Components/Containers

1800668-01 FOAM1804061515JLB 06-Apr-18 15:15 13-Apr-18 09:40 HDPE Bottle, 250 mL

1800668-02 EB1804091600JLB 09-Apr-18 16:00 13-Apr-18 09:40 HDPE Bottle, 250 mL

Vista Project: 1800668 Client Project: MDEQ North Kent PFAS


ANALYTICAL RESULTS


Name:

Project:

Client Data

MDEQ North Kent PFAS

Sample ID: Method Blank

Matrix:

Laboratory Data

Lab Sample: B8D0132-BLK1


Merit Laboratories, Inc. Column: BEH C18Aqueous

Analyte Conc. (ng/L) Qualifiers Analyzed DilutionLOD LOQDL Batch Extracted Samp SizeCAS Number

PFBA 0.365ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18375-22-4

PFPeA 0.640ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-182706-90-3

PFBS 0.895ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18375-73-5

PFHxA 1.09ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18307-24-4

PFHpA 0.296ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18375-85-9

PFHxS 0.474ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18355-46-4

6:2 FTS 1.00ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-1827619-97-2

PFOA 0.580ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18335-67-1

PFHpS 0.469ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18375-92-8

PFOS 0.4040.434 J 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-181763-23-1

PFNA 0.405ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18375-95-1

PFDA 0.745ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18335-76-2

8:2 FTS 1.03ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-1839108-34-4

PFOSA 0.885ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18754-91-6

MeFOSAA 0.825ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-182355-31-9

PFDS 0.615ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18335-77-3

PFUnA 0.525ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-182058-94-8

EtFOSAA 0.685ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-182991-50-6

PFDoA 0.396ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18307-55-1

PFTrDA 0.247ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-1872629-94-8

PFTeDA 0.378ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18376-06-7

PFNS 1.94ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-1868259-12-1

PFPeS 1.21ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-182706-91-4

4:2 FTS 0.695ND 12.50 4.00 16-May-18 14:44B8D0132 0.250 L19-Apr-18757124-72-4

Labeled Standards % Recovery Limits Qualifiers Analyzed DilutionType Batch Extracted Samp Size

IS - 13C3-PFBA 102 60 130 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C3-PFPeA 105 60 150 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C3-PFBS 128 60 150 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C2-PFHxA 107 70 130 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C4-PFHpA 112 60 150 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 18O2-PFHxS 95.3 60 130 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C2-PFOA 82.6 60 130 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C8-PFOS 104 60 130 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C5-PFNA 91.7 50 130 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C2-PFDA 94.5 60 130 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C8-PFOSA 35.1 20 150 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - d3-MeFOSAA 62.0 50 150 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C2-PFUnA 74.8 60 130 116-May-18 14:44B8D0132 19-Apr-18 0.250 L


Name:

Project:

Client Data


Sample ID: Method Blank

Matrix:

Laboratory Data

Lab Sample: B8D0132-BLK1




IS - d5-EtFOSAA 67.8 50 150 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C2-PFDoA 84.4 30 130 116-May-18 14:44B8D0132 19-Apr-18 0.250 L

IS - 13C2-PFTeDA 68.0 20 150 116-May-18 14:44B8D0132 19-Apr-18 0.250 LLCL-UCL- Lower control limit - upper control limit

Results reported to the DL. DL - Detection Limit When reported, PFHxS, PFOA and PFOS include both linear and branched isomers.

Only the linear isomer is reported for all other analytes. LOD - Limit of Detection

LOQ - Limit of quantitation


Name:Project:

Client Data


Sample ID: OPR

Matrix:

Laboratory Data

Lab Sample: B8D0132-BS1



Analyte Amt Found (ng/L) Qualifiers Analyzed DilutionSpike Amt % Rec Limits Samp SizeExtractedBatchCAS Number

PFBA 48.9 116-May-18 14:3240.0 122 - 70 130 0.250 L19-Apr-18B8D0132375-22-4

PFPeA 48.4 116-May-18 14:3240.0 121 - 70 130 0.250 L19-Apr-18B8D01322706-90-3

PFBS 51.4 116-May-18 14:3240.0 129 - 70 130 0.250 L19-Apr-18B8D0132375-73-5

PFHxA 54.2 H 116-May-18 14:3240.0 136 - 70 130 0.250 L19-Apr-18B8D0132307-24-4

PFHpA 48.8 116-May-18 14:3240.0 122 - 70 130 0.250 L19-Apr-18B8D0132375-85-9

PFHxS 50.8 116-May-18 14:3240.0 127 - 70 130 0.250 L19-Apr-18B8D0132355-46-4

6:2 FTS 51.2 116-May-18 14:3240.0 128 - 60 130 0.250 L19-Apr-18B8D013227619-97-2

PFOA 51.7 116-May-18 14:3240.0 129 - 70 130 0.250 L19-Apr-18B8D0132335-67-1

PFHpS 69.1 H 116-May-18 14:3240.0 173 - 60 130 0.250 L19-Apr-18B8D0132375-92-8

PFOS 52.1 B 116-May-18 14:3240.0 130 - 70 130 0.250 L19-Apr-18B8D01321763-23-1

PFNA 53.2 H 116-May-18 14:3240.0 133 - 70 130 0.250 L19-Apr-18B8D0132375-95-1

PFDA 51.7 116-May-18 14:3240.0 129 - 70 130 0.250 L19-Apr-18B8D0132335-76-2

8:2 FTS 54.5 H 116-May-18 14:3240.0 136 - 60 130 0.250 L19-Apr-18B8D013239108-34-4

PFOSA 53.3 H 116-May-18 14:3240.0 133 - 70 130 0.250 L19-Apr-18B8D0132754-91-6

MeFOSAA 47.4 116-May-18 14:3240.0 119 - 70 130 0.250 L19-Apr-18B8D01322355-31-9

PFDS 73.7 H 116-May-18 14:3240.0 184 - 60 130 0.250 L19-Apr-18B8D0132335-77-3

PFUnA 58.1 H 116-May-18 14:3240.0 145 - 70 130 0.250 L19-Apr-18B8D01322058-94-8

EtFOSAA 54.8 H 116-May-18 14:3240.0 137 - 70 130 0.250 L19-Apr-18B8D01322991-50-6

PFDoA 67.1 H 116-May-18 14:3240.0 168 - 70 130 0.250 L19-Apr-18B8D0132307-55-1

PFTrDA 59.6 H 116-May-18 14:3240.0 149 - 60 130 0.250 L19-Apr-18B8D013272629-94-8

PFTeDA 50.8 116-May-18 14:3240.0 127 - 70 130 0.250 L19-Apr-18B8D0132376-06-7

PFNS 47.5 116-May-18 14:3240.0 119 - 70 130 0.250 L19-Apr-18B8D013268259-12-1

PFPeS 45.8 116-May-18 14:3240.0 115 - 70 130 0.250 L19-Apr-18B8D01322706-91-4

4:2 FTS 54.4 H 116-May-18 14:3240.0 136 - 60 130 0.250 L19-Apr-18B8D0132757124-72-4

Labeled Standards % Rec Limits Qualifiers Analyzed DilutionType Samp SizeExtractedBatch

IS - 13C3-PFBA 103 60 130 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C3-PFPeA 102 60 150 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C3-PFBS 145 60 150 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C2-PFHxA 99.1 70 130 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C4-PFHpA 101 60 150 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 18O2-PFHxS 109 60 130 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C2-PFOA 93.4 60 130 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C8-PFOS 109 60 130 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C5-PFNA 96.0 50 130 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C2-PFDA 94.1 60 130 116-May-18 14:320.250 L19-Apr-18B8D0132


Name:Project:

Client Data


Sample ID: OPR

Matrix:

Laboratory Data

Lab Sample: B8D0132-BS1



Labeled Standards % Rec Limits Qualifiers Analyzed DilutionType Samp SizeExtractedBatch

IS - 13C8-PFOSA 34.2 20 150 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - d3-MeFOSAA 74.5 50 150 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C2-PFUnA 72.1 60 130 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - d5-EtFOSAA 73.2 50 150 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C2-PFDoA 72.8 30 130 116-May-18 14:320.250 L19-Apr-18B8D0132

IS - 13C2-PFTeDA 91.5 20 150 116-May-18 14:320.250 L19-Apr-18B8D0132


Name:

Project: Date Collected:

Client Data


Sample ID: FOAM1804061515JLB

Matrix:

Laboratory Data

Lab Sample: 1800668-01



06-Apr-18 15:15 Date Received: 13-Apr-18 09:40

Location: ROCKFORD DAM-ROGUE






PFHpA 1.5128.1 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-18375-85-9

PFHxS 2.4217.4 J 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-18355-46-4

6:2 FTS 5.11ND 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-1827619-97-2

PFOA 2.96255 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-18335-67-1

PFHpS 2.39606 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-18375-92-8

PFOS 61.8261000 B, D 30383 613 23-May-18 14:26B8D0132 0.0489 L19-Apr-181763-23-1

PFNA 2.07744 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-18375-95-1

PFDA 3.811020 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-18335-76-2

8:2 FTS 5.26ND 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-1839108-34-4

PFOSA 4.521760 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-18754-91-6

MeFOSAA 4.211310 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-182355-31-9

PFDS 3.14632 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-18335-77-3

PFUnA 2.681060 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-182058-94-8

EtFOSAA 10528000 D 30383 613 23-May-18 14:26B8D0132 0.0489 L19-Apr-182991-50-6

PFDoA 2.02133 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-18307-55-1

PFTrDA 1.2619.1 J 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-1872629-94-8




4:2 FTS 3.55ND 112.8 20.4 16-May-18 14:55B8D0132 0.0489 L19-Apr-18757124-72-4


IS - 13C3-PFBA 99.3 60 130 116-May-18 14:55B8D0132 19-Apr-18 0.0489 L

IS - 13C3-PFPeA 94.8 60 150 116-May-18 14:55B8D0132 19-Apr-18 0.0489 L


IS - 13C2-PFHxA 85.6 70 130 116-May-18 14:55B8D0132 19-Apr-18 0.0489 L

IS - 13C4-PFHpA 92.7 60 150 116-May-18 14:55B8D0132 19-Apr-18 0.0489 L

IS - 18O2-PFHxS 97.0 60 130 116-May-18 14:55B8D0132 19-Apr-18 0.0489 L


IS - 13C8-PFOS 82.2 60 130 D 3023-May-18 14:26B8D0132 19-Apr-18 0.0489 L







Name:


Client Data


Sample ID: FOAM1804061515JLB

Matrix:

Laboratory Data





Location: ROCKFORD DAM-ROGUE


IS - d5-EtFOSAA 64.1 50 150 D 3023-May-18 14:26B8D0132 19-Apr-18 0.0489 L







Name:


Client Data


Sample ID: EB1804091600JLB

Matrix:

Laboratory Data





Location: CLOTH-EB






PFHpA 0.294ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-18375-85-9

PFHxS 0.472ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-18355-46-4

6:2 FTS 0.996ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-1827619-97-2

PFOA 0.578ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-18335-67-1

PFHpS 0.467ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-18375-92-8

PFOS 0.402ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-181763-23-1

PFNA 0.403ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-18375-95-1

PFDA 0.742ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-18335-76-2

8:2 FTS 1.03ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-1839108-34-4

PFOSA 0.882ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-18754-91-6

MeFOSAA 0.822ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-182355-31-9

PFDS 0.613ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-18335-77-3

PFUnA 0.523ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-182058-94-8

EtFOSAA 0.682ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-182991-50-6

PFDoA 0.394ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-18307-55-1

PFTrDA 0.246ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-1872629-94-8




4:2 FTS 0.692ND 12.49 3.98 16-May-18 15:07B8D0132 0.251 L19-Apr-18757124-72-4


IS - 13C3-PFBA 105 60 130 116-May-18 15:07B8D0132 19-Apr-18 0.251 L

IS - 13C3-PFPeA 109 60 150 116-May-18 15:07B8D0132 19-Apr-18 0.251 L


IS - 13C2-PFHxA 91.8 70 130 116-May-18 15:07B8D0132 19-Apr-18 0.251 L

IS - 13C4-PFHpA 109 60 150 116-May-18 15:07B8D0132 19-Apr-18 0.251 L

IS - 18O2-PFHxS 109 60 130 116-May-18 15:07B8D0132 19-Apr-18 0.251 L


IS - 13C8-PFOS 104 60 130 116-May-18 15:07B8D0132 19-Apr-18 0.251 L







Name:


Client Data


Sample ID: EB1804091600JLB

Matrix:

Laboratory Data





Location: CLOTH-EB


IS - d5-EtFOSAA 71.1 50 150 116-May-18 15:07B8D0132 19-Apr-18 0.251 L







DATA QUALIFIERS & ABBREVIATIONS B This compound was also detected in the method blank Conc. Concentration D Dilution DL Detection limit E The associated compound concentration exceeded the calibration range of

the instrument H Recovery and/or RPD was outside laboratory acceptance limits I Chemical Interference J The amount detected is below the Reporting Limit/LOQ LOD Limits of Detection LOQ Limits of Quantitation M Estimated Maximum Possible Concentration (CA Region 2 projects only) NA Not applicable ND Not Detected Q Ion ratio outside of 70-130% of Standard Ratio. (DOD PFAS projects only) TEQ Toxic Equivalency U Not Detected (specific projects only) * See Cover Letter Unless otherwise noted, solid sample results are reported in dry weight. Tissue samples are reported in wet weight.


CERTIFICATIONS

Accrediting Authority Certificate Number Alaska Department of Environmental Conservation 17-013

Arkansas Department of Environmental Quality 17-015-0

California Department of Health – ELAP 2892

DoD ELAP - A2LA Accredited - ISO/IEC 17025:2005 3091.01

Florida Department of Health E87777-18

Hawaii Department of Health N/A

Louisiana Department of Environmental Quality 01977

Maine Department of Health 2016026

Minnesota Department of Health 1322288

New Hampshire Environmental Accreditation Program 207717

New Jersey Department of Environmental Protection CA003

New York Department of Health 11411

Oregon Laboratory Accreditation Program 4042-008

Pennsylvania Department of Environmental Protection 014

Texas Commission on Environmental Quality T104704189-17-8

Virginia Department of General Services 9077

Washington Department of Ecology C584

Wisconsin Department of Natural Resources 998036160

Current certificates and lists of licensed parameters are located in the Quality Assurance office and are available upon request.


S MICHIGAN RICK SNYDER DEPARTMENT OF HEALTH AND … · oral RfD for PFOA and PFOS of 20 ng/kg/day....

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Transcript of S MICHIGAN RICK SNYDER DEPARTMENT OF HEALTH AND … · oral RfD for PFOA and PFOS of 20 ng/kg/day....