PHILIP D. MURPHY DEPARTMENT OF ENVIRONMENTAL PROTECTION Site Remediation and Waste Management Program CATHERINE R: MCCABE Governor . 401 E. State Street Commisszoner SHEILA Y. OLIVER PO Box 420, Mail Code 401-06 Lt. Governor Trenton, New Jersey 08625 Tel: (609) 292?1250 Fax: (609) 777-1914 April 8, 2019 John Prince, Acting Director Emergency Remedial Response Division United States Environmental Protection Agency Region II 290 Broadway Mail Code: 26th Fl New York, New York 10007-1866 Re: Sampling for contaminants of emerging concern Emerging Contaminants) Dear Mr. Prince: This letter is a follow-up to our meeting on September 20, 2018 when we discussed implementing an expanded sampling program for emerging contaminants at all National Priorities List (NPL) sites to determine their presence in groundwater and surface water at sites across the state. Please accept this letter as a formal request from the New Jersey Department of Environmental Protection (the Department) to the U.S. Environmental Protection Agency Region 2 Emergency Remedial Response Division (EPA) to conduct a review of each NPL site for the following contaminants in groundwater, surface water and site-related treatment systems: 0 1,4-dioxane I perfluorononanoic acid (PFNA) perfluorooctanoic acid (PFOA) I perfluorooctane sulfonic acid (PFOS) - 1,2,3-trichloropropane I perchlorate New Jersey recently promulgated Ground Water Quality Standards for 1,4-dioxane and perchlorate and a Maximum Contaminant Level (MCL) for PFNA and 1,2,3 TCP. The Department has just published Interim Specific Ground Water Quality Criteria for PFOA and therefore, these contaminants should be considered Applicable or Relevant and Appropriate Requirements (ARARs) for any remedial action. These compounds also should be included in The State of New Jersey is an equal opportunity employer. Printed on recycied and recyclable paper. any upcoming required Five?Year Review at NPL sites to ensure that any previously implemented site remedy remains protective. The Department suggests that EPA prioritize sampling at sites where it is likely to find these compounds and receptors may be a concern. As you know, the Department has detected 1,4- dioxane at several landfill sites and at sites with chlorinated solvents, especially 1,1,1- trichloroethane. is most often associated with fumigants used in agriculture and is usually co?located with 1,2-dichloropropane requires a special pesticide analysis, however, can be detected by a volatile organic compound (VOC) scan. Reviewing prior VOC analyses for detection of would indicate a need to sample for Perchlorate is not a routine analyte and requires a special analysis. it is primarily associated with agricultural use, but can also be found at industrial facilities such as the Shieldalloy NPL site and others where energetic compounds may be present. information on PFNA and other per- and polyfluoroalkyl substances (PFAS) compounds can be found at many different sites, and EPA and Interstate Technology Regulatory Council guidance is available to identify the various industries and sites where these compounds are likely to be found. As we noted at the December 2018 meeting, Curtis Paper is a likely candidate for PFAS sampling based on the products they manufactured. Landfills and other sites where chemical wastes were disposed BROS) should also be prioritized. The Department recommends that EPA analyze for the entire suite of PFAS compounds using revised EPA Method 537.1 as part ofthis effort to capture an expanded list of PFAS, including GenX. Please let me know if you have any questions regarding this request. The Department would like to coordinate sampling of the NPL sites. Edward Putnam will be the Department lead for this effort; he can be contacted at (609) 984?9769 or Ed.Putnam@dep.ni.gov. - Mark. Pedersen I Assis ant Commi sioner Site emediation Waste Management Program C: Kenneth J. Kloo, Director DRM David Haymes, Director, DETFS Edward Putnam, Assistant Director, PFRE Stephen Maybury, Bureau Chief, BCM Frederick Mumford, Section Chief, BEMSA