ASTM E3358-23a

Standard Guide for Per- and Polyfluoroalkyl Substances Site Screening and Initial Characterization

SIGNIFICANCE AND USE
4.1 PFAS are widely used in commercial and industrial applications worldwide (see Fig. 1). PFAS are of concern due to their documented persistence and their studied impacts on human health and the environmental. While there is no comprehensive source of information on the many individual PFAS substances and their functions in different applications, a range of resources are available to the practitioner. This guide provides information to assist the practitioner in navigating these challenges during the initial screening and site characterization process.
FIG. 1 Activity/Industry that may be Sources of PFAS Use and Release
Source: AEI Consultants  
4.2 The user should note that PFAS regulatory management framework at the federal and state level are evolving quickly. Therefore, consultation with legal and technical representatives with knowledge of federal, state, and local PFAS regulations is advised prior to use of this guide. Environmental audit policies or privileges may be applicable to some of the steps described in this guide (see EPA, 2000).  
4.3 Multi-step Risk Management Framework:  
4.3.1 The actions described in this guide are intended to provide a multi-step risk management framework to confirm, with reasonable certainty, that PFAS may have been used at a federally-owned, publicly-owned, or privately-owned property. This standard provides guidance on how to focus limited resources on using a multi-step process, illustrated in Fig. 2, to identify property potentially impacted by on-site or off-site uses and releases of PFAS. Section 4.5 describes the use and occurrence of PFAS. Section 4.6 describes activities at government and federal installations where PFAS use is expected. Section 4.7 broadly outlines the industry sectors where the use of PFAS has been documented (Glüge, 2020 (2), Gaines, 2022 (3)).
FIG. 2 Initial Site Screening and Characterization Flow Diagram  
4.4 PFAs History and Use:  
4.4.1 In the 1940s, industrial processes to co...
SCOPE
1.1 Per- and polyfluoroalkyl substances (PFAS) are a group of over 7,000 manmade compounds consisting of polymeric chains of carbon bonded to fluorine atoms, usually with a polar functional group at the head. This guide recognizes that PFAS can be categorized as polymeric or nonpolymeric, collectively amounting to more than 4,700 Chemical Abstracts Service (CAS)-registered substances. Environmental concerns pertaining to PFAS are centered primarily on the perfluoroalkyl acids (PFAA), a subclass of per-and polyfluoroalkyl substances, which display extreme persistence and chain-length dependent bioaccumulation and adverse effects in biota.  
1.2 The regulatory framework for PFAS continues to evolve, both domestically and internationally. The United States Environmental Protection Agency (EPA) is proceeding with a wide-ranging set of PFAS regulatory actions (EPA, 2021). While the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) does not currently recognize PFAS as hazardous substances, the statute does require actions to protect public health and the environment from contaminants and pollutants released to the environment. Other federal regulatory programs, such as the Safe Drinking Water Act are being used to address drinking water supplies adversely impacted by releases of PFAS. The Clean Water Act’s National Pollutant Discharge Elimination System (NPDES) permitting program is tool that both federal and state regulators are using to regulate the inflows of PFAS-impacted wastewaters at both publicly-owned treatment works (POTW) and federally-owned wastewater treatment plants and the concentration of PFAS in permitted effluent. EPA continues to add additional per-and polyfluoroalkyl substances to the list of substances reportable under the federal Toxic Release Inventory (TRI) reporting program. International efforts to address per-and polyfluoroalkyl substances include Australia’s PFAS Nation...

General Information

• Status: Published
• Publication Date: 31-Jul-2023
• ICS: 71.040.50 - Physicochemical methods of analysis
• Technical Committee: E50 - Environmental Assessment, Risk Management and Corrective Action
• Drafting Committee: E50.04 - Corrective Action

Relations

• Refers: ASTM E3123-24 - Standard Guide for Recognition and Derecognition of Environmental Liabilities
• Effective Date: 01-Mar-2024
• Refers: ASTM E3274-24 - Standard Guide for Management of Investigation-Derived Waste Associated with PFAS
• Effective Date: 01-Feb-2024
• Refers: ASTM E3302-23 - Standard Guide for PFAS Analytical Methods Selection
• Effective Date: 15-Dec-2023
• Refers: ASTM E2247-23 - Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property
• Effective Date: 01-Nov-2023
• Refers: ASTM D7968-23 - Standard Test Method for Determination of Polyfluorinated Compounds in Soil by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)
• Effective Date: 01-Nov-2023
• Refers: ASTM D7979-20 - Standard Test Method for Determination of Per- and Polyfluoroalkyl Substances in Water, Sludge, Influent, Effluent, and Wastewater by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)
• Effective Date: 15-Aug-2020
• Refers: ASTM E1903-19 - Standard Practice for Environmental Site Assessments: Phase II Environmental Site Assessment Process
• Effective Date: 15-Nov-2019
• Refers: ASTM D7979-19 - Standard Test Method for Determination of Per- and Polyfluoroalkyl Substances in Water, Sludge, Influent, Effluent, and Wastewater by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)
• Effective Date: 01-Nov-2019
• Refers: ASTM D6235-18 - Standard Practice for Expedited Site Characterization of Vadose Zone and Groundwater Contamination at Hazardous Waste Contaminated Sites
• Effective Date: 15-Dec-2018
• Refers: ASTM E3123-18 - Standard Guide for Recognition and Derecognition of Environmental Liabilities
• Effective Date: 01-Feb-2018
• Refers: ASTM E3123-17 - Standard Guide for Recognition and Derecognition of Environmental Liabilities
• Effective Date: 15-Oct-2017
• Refers: ASTM D7968-17a - Standard Test Method for Determination of Polyfluorinated Compounds in Soil by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)
• Effective Date: 01-Sep-2017
• Refers: ASTM D7979-17 - Standard Test Method for Determination of Per- and Polyfluoroalkyl Substances in Water, Sludge, Influent, Effluent and Wastewater by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)
• Effective Date: 15-Jul-2017
• Refers: ASTM D7968-17 - Standard Test Method for Determination of Polyfluorinated Compounds in Soil by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)
• Effective Date: 01-May-2017
• Refers: ASTM E2247-16 - Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property
• Effective Date: 01-Dec-2016

Overview

ASTM E3358-23a: Standard Guide for Per- and Polyfluoroalkyl Substances Site Screening and Initial Characterization provides a comprehensive framework for identifying the potential use and release of PFAS (Per- and polyfluoroalkyl substances) at commercial, industrial, and government properties. PFAS are a class of over 7,000 manmade chemicals known for their persistence in the environment and bioaccumulative properties, raising significant human health and ecological concerns. This guide assists practitioners in navigating the challenges of PFAS screening and characterization by offering a multi-step, risk-based process to determine if a property has been impacted by PFAS, emphasizing careful resource allocation and compliance with evolving regulatory requirements.

Key Topics

• PFAS Definition and Concerns

  • PFAS consist of polymeric chains of carbon and fluorine, often with a polar functional group.
  • Environmental and health risks are mainly attributed to perfluoroalkyl acids (PFAA), a PFAS subclass, due to their extreme persistence and potential for bioaccumulation.

• Regulatory Landscape

  • PFAS regulations are rapidly changing at the federal, state, and international levels.
  • Major regulatory actions are in progress by the US EPA and other agencies under the Safe Drinking Water Act, Clean Water Act, and Toxic Release Inventory reporting.
  • International efforts include Australia’s PFAS National Environmental Management Plan, Canada’s Toxic Substances Regulations, the Stockholm Convention, and the EU Water Framework Directive.

• Multi-Step Risk Management Framework

  • The guide outlines a tiered, resource-efficient process for site screening and characterization, incorporating best practices and recognized decision frameworks.
  • Users are encouraged to consult with legal and technical experts to ensure compliance with the latest regulations.

• Historical and Current Uses of PFAS

  • Since their commercial introduction in the 1940s, PFAS have been widely used in surface treatments, firefighting foams (AFFF), food packaging, textiles, and industrial processes.
  • Sources of PFAS releases include manufacturing emissions, wastewater discharges, landfills, and application of contaminated biosolids.

Applications

• Environmental Site Assessment

  • Practitioners can use this guide as a supplemental resource during Phase I and Phase II Environmental Site Assessments to screen for potential PFAS contamination.
  • The guide supports identification and prioritization of site investigation efforts, helping to inform risk management and remediation planning.

• Industrial and Government Properties

  • Especially relevant for sites with historical or ongoing activities such as firefighting training, chemical manufacturing, metal plating, and waste treatment.
  • Useful for federal installations, refineries, airports, and municipalities managing potential PFAS risks.

• Risk Decision Making

  • Enables informed decisions about resource allocation for further investigation, monitoring, and corrective action related to PFAS contamination.
  • Assists in the development of conceptual site models to understand contaminant transport and exposure scenarios.

Related Standards

• ASTM D6008 - Environmental Condition of Federal Property
• ASTM D6235 - Expedited Site Characterization
• ASTM D7968, D7979, D8421 - PFAS Analytical Methods
• ASTM E1527, E1689, E1903 - Environmental Site Assessments
• ASTM E2081, E2205 - Risk-Based Corrective Action
• ASTM E3274 - Management of Investigation-Derived Waste Associated with PFAS
• ASTM E3302 - PFAS Analytical Methods Selection
• ISO 21365:2019 - Soil Quality-Conceptual Site Models for Potentially Contaminated Sites

ASTM E3358-23a is a vital resource for environmental professionals responsible for the screening, assessment, and management of PFAS risks, supporting compliance, due diligence, and best practices for safeguarding human health and the environment. For the most up-to-date guidance, users should always reference the current version and consult appropriate regulatory authorities.

Standards Content (Sample)

This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: E3358 − 23a
Standard Guide for
Per- and Polyfluoroalkyl Substances Site Screening and
Initial Characterization
This standard is issued under the fixed designation E3358; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
INTRODUCTION
This guide discusses the key decision considerations and best practices for the screening and initial
characterization of sites to evaluate the potential release of per- and polyfluoroalkyl substances (PFAS)
into the environment. This guide provides a flexible, defensible framework applicable to a wide range
of environment programs. It is structured to support a tiered approach with procedures and techniques
of increasing complexity as the user proceeds through the site evaluation process to aid users in
achieving project objectives. There are numerous technical policy decisions that must be made in the
screening and initial characterization of sites. It is not the intent of this guide to define appropriate
technical policy decisions, but rather to provide technical support within existing decision frame-
works.
1. Scope Act’s National Pollutant Discharge Elimination System
(NPDES) permitting program is tool that both federal and state
1.1 Per- and polyfluoroalkyl substances (PFAS) are a group
regulators are using to regulate the inflows of PFAS-impacted
of over 7,000 manmade compounds consisting of polymeric
wastewaters at both publicly-owned treatment works (POTW)
chains of carbon bonded to fluorine atoms, usually with a polar
and federally-owned wastewater treatment plants and the
functional group at the head. This guide recognizes that PFAS
concentration of PFAS in permitted effluent. EPA continues to
can be categorized as polymeric or nonpolymeric, collectively
add additional per-and polyfluoroalkyl substances to the list of
amounting to more than 4,700 Chemical Abstracts Service
substances reportable under the federal Toxic Release Inven-
(CAS)-registered substances. Environmental concerns pertain-
tory (TRI) reporting program. International efforts to address
ing to PFAS are centered primarily on the perfluoroalkyl acids
per-and polyfluoroalkyl substances include Australia’s PFAS
(PFAA), a subclass of per-and polyfluoroalkyl substances,
National Environmental Management Plan, Version 2 (2020),
which display extreme persistence and chain-length dependent
Canada’s Prohibition of Certain Toxic Substances Regulations,
bioaccumulation and adverse effects in biota.
(2022), the Stockholm Convention on Persistent Organic
1.2 The regulatory framework for PFAS continues to evolve,
Pollutants, and the European Union’s Water Framework Direc-
both domestically and internationally. The United States Envi-
tive (1).
ronmental Protection Agency (EPA) is proceeding with a
wide-ranging set of PFAS regulatory actions (EPA, 2021).
1.3 Hazardous waste treatment, storage, and disposal facili-
While the Comprehensive Environmental Response, ties (TSDF) currently operating under the Resource Conserva-
Compensation, and Liability Act (CERCLA) does not currently
tion and Recovery Act (RCRA) via a Part B Permit may be
recognize PFAS as hazardous substances, the statute does
ordered to investigate releases of PFAS under a RCRA Correc-
require actions to protect public health and the environment
tive Action order. EPA made a policy decision in the 1990s to
from contaminants and pollutants released to the environment.
defer many potential CERCLA enforcement actions to the
Other federal regulatory programs, such as the Safe Drinking
RCRA Corrective Action Program (EPA, 1999). Permitted
Water Act are being used to address drinking water supplies
TSDFs at refineries may be subject to RCRA Corrective Action,
adversely impacted by releases of PFAS. The Clean Water
as opposed to other regulatory programs, to address the
releases of PFAS associated past and current use of aqueous
film-forming foam (AFFF).
This guide is under the jurisdiction of ASTM Committee E50 on Environmental
Assessment, Risk Management and Corrective Action and is the direct responsibil-
ity of Subcommittee E50.04 on Corrective Action.
Current edition approved Aug. 1, 2023. Published August 2023. Originally
approved in 2023. Last previous edition approved in 2023 as E3358–23. DOI: The boldface numbers in parentheses refer to the list of references at the end of
10.1520/E3358–23A this standard.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E3358 − 23a
1.4 Numerous states and Tribes are using their existing mendations issued by the World Trade Organization Technical
regulatory programs to direct investigation, site remediation, Barriers to Trade (TBT) Committee.
and correction action related to releases of PFAS to soil,
2. Referenced Documents
groundwater, and surface waters. These actions range from
health advisories and guidelines to enforceable regulatory
2.1 ASTM Standards:
standards. Regulatory considerations include PFAS risks to D6008 Practice for Determining the Environmental Condi-
both human health and ecological receptors that are protected
tion of Federal Property
under a broad array of federal, state, and tribal regulatory D6235 Practice for Expedited Site Characterization of Va-
programs as well as by treaty rights.
dose Zone and Groundwater Contamination at Hazardous
Waste Contaminated Sites
1.5 This guide assists users in the identification of real
D7968 Test Method for Determination of Polyfluorinated
property concerns that may be the source of PFASreleases or
Compounds in Soil by Liquid Chromatography Tandem
that may be adversely impacted by releases of PFAS. The goal
Mass Spectrometry (LC/MS/MS)
of this guide is to assist managers of environmental risk in their
D7979 Test Method for Determination of Per- and Polyfluo-
resource allocation decision-making.
roalkyl Substances in Water, Sludge, Influent, Effluent,
1.6 This guide does not constitute “All Appropriate Inqui-
and Wastewater by Liquid Chromatography Tandem Mass
ries” as defined in 40 CFR Part 312 and is not intended to
Spectrometry (LC/MS/MS)
provide the user with any of the landowner liability protections
D8421 Test Method for Determination of Per- and Polyfluo-
codified in CERCLA §101(35)(A)(i), CERCLA
roalkyl Substances (PFAS) in Aqueous Matrices by Co-
§101(40)(B)(iii), or CERCLA §107(q)(1)(A)(viii).
solvation followed by Liquid Chromatography Tandem
Mass Spectrometry (LC/MS/MS)
1.7 This guide describes widely accepted considerations and
E29 Practice for Using Significant Digits in Test Data to
best practices used in the site screening and initial site
Determine Conformance with Specifications
characterization process, with specific consideration of the
E1527 Practice for Environmental Site Assessments: Phase I
potential for the release of PFAS into the environment. This
Environmental Site Assessment Process
guide complements but does not replace existing technical
E1689 Guide for Developing Conceptual Site Models for
guidance and regulatory requirements.
Contaminated Sites
1.8 This guide does not address and is not applicable to
E1903 Practice for Environmental Site Assessments: Phase
sampling and analysis of public or private domestic water
II Environmental Site Assessment Process
supply systems subject to regulation under the Safe Drinking
E2020 Guide for Data and Information Options for Conduct-
Water Act and state private well testing act requirements.
ing an Ecological Risk Assessment at Contaminated Sites
Regulatory agencies responsible for implementing the Safe
E2081 Guide for Risk-Based Corrective Action
Drinking Water Act may have established sampling and report-
E2173 Guide for Disclosure of Environmental Liabilities
ing requirements for public, community, and privately operated
E2205 Guide for Risk-Based Corrective Action for Protec-
water systems.
tion of Ecological Resources
E2247 Practice for Environmental Site Assessments: Phase I
1.9 All references to specific federal or state programs are
Environmental Site Assessment Process for Forestland or
current as of the date of publication. The user is cautioned not
Rural Property
to rely on this guide alone but to consult directly with the
E3123 Guide for Recognition and Derecognition of Envi-
appropriate program and legal counsel regarding this complex
ronmental Liabilities
and rapidly evolving concern.
E3274 Guide for Management of Investigation-Derived
1.10 This guide is intended to complement, not replace,
Waste Associated with PFAS
existing regulatory requirements or guidance. ASTM Interna-
E3302 Guide for PFAS Analytical Methods Selection
tional (ASTM) guides are not regulations; they are consensus-
2.2 Other Referenced Documetns:
based standards that may be followed as needed.
Agency for Toxic Substances and Disease Registry, Toxico-
logical Profile for Perfluoroalkyls, May 2021
1.11 Units—The values stated in SI units are to be regarded
California Office of Environmental Health Hazard Assess-
as the standard. Other units, such as fractional units of parts per
ment, Toxicity Criteria Database, https://data.ca.gov/
billion (ppb) and parts per trillion (ppt), are also included in
dataset/toxicity-criteria-database, May 2019
this guide.
California Department of Toxic Substances Control, Prelimi-
1.12 This standard does not purport to address all of the
nary Endangerment Assessment Manual, 2015
safety concerns, if any, associated with its use. It is the
CRC CARE 2018, Technical Report 43, Practitioner guide to
responsibility of the user of this standard to establish appro-
risk-based assessment, remediation and management of
priate safety, health, and environmental practices and deter-
PFAS site contamination
mine the applicability of regulatory limitations prior to use.
1.13 This international standard was developed in accor-
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
dance with internationally recognized principles on standard-
contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM
ization established in the Decision on Principles for the
Standards volume information, refer to the standard’s Document Summary page on
Development of International Standards, Guides and Recom- the ASTM website.
E3358 − 23a
Department of Defense Instruction 4715.18, Emerging 3. Terminology
Chemicals (ECs) of Environmental Concern, September
3.1 This section provides definitions of terms not unique to
4, 2019
this practice, descriptions of terms specific to this practice, and
ISO 21365:2019 Soil quality — Conceptual site models for
a list of acronyms and abbreviations used herein. The terms are
potentially contaminated sites
an integral part of this guide and are critical to its understand-
OECD, Lists of PFOS, PFAS, PFOA, PFCA Related Com-
ing and use.
pounds and Chemicals that may Degrade to PFCA.
3.2 Definitions:
Environment, Health and Safety Publications Series on
3.2.1 aqueous film forming foam (AFFF), n—a fire suppres-
Risk Management No. 21, ENV/JM/MONO (2006, rev.
sant used to extinguish flammable liquid fires such as fuel fires.
2007)15, 157 pp.
3.2.1.1 Discussion—Aqueous film forming foam is often
Pubchem Databases, pubchem.ncbi.nlm.nih.gov
used in shipboard and shore facility fire suppression systems,
2.3 USEPA References and Databases:
fire fighting vehicles, and at fire training facilities. AFFF may
Envirofacts (https://enviro.epa.gov/): A single point of ac-
be used to prevent fires at sites where alcohol-based products
cess to select U.S. EPA environmental data. This website
are potential fuel sources. Industrial facilities, such as refineries
provides access to several EPA databases to provide the
and petroleum terminals, with large quantities of flammable
user with information about environmental activities that
and combustible liquids in storage often use AFFF in the
may affect air, water, and land anywhere in the United
facility’s fire suppression system.
States
3.2.2 conceptual site model, n—for the purpose of this
Superfund Enterprise Management System (https://
guide, a written or pictorial representation of an environmental
www.epa.gov/enviro/sems-search)
system and the biological, physical, and chemical processes
FEDFacts (https://www.epa.gov/fedfac): Information about
that determine the transport of contaminants from sources
the Federal Electronic Docket Facilities regarding con-
through environmental media to human and ecological recep-
taminated federal facility sites in specific communities,
tors within the system (see Guide E1689.)
technical fact sheets and tools and resources to help
3.2.3 contaminated public wells, n—public wells used for
government agencies and their contractors fulfill cleanup
drinking water that have been designated by a government
obligations
entity as contaminated by toxic substances (for example,
U.S. EPA, Incentives for Self-Policing: Discovery,
chlorinated solvents), or as having water unsafe to drink
Disclosure, Correction and Prevention of Violations;
without treatment.
Notice, 65 FR 19618, April 11, 2000
U.S. EPA, Guidance on Systematic Planning Using the Data
3.2.4 drum, n—as defined by the U.S. Department of
Quality Objectives Process, EPA QA/G-4, EPA/240/B-06-
Transportation, is a flat-ended or convex-ended cylindrical
01, 2006
packaging made of metal, fiberboard, plastic, plywood, or other
U.S. EPA, Comptox Dashboard: https://comptox.epa.gov/
suitable materials; this definition does not include cylinders,
dashboard
jerricans, wooden barrels or bulk packagings.
U.S. EPA, ECOTOX database; https://cfpub.epa.gov/
3.2.4.1 Discussion—At federal facilities, a metal or plastic
ecotox/index.cfm
container (typically, but not necessarily, holding 55 gal [208 L]
U.S. EPA, Health and Environmental Research Online
of liquid) that may have been used to store hazardous sub-
(HERO) https;//hero.epa.gov/hero
stances or petroleum products.
U.S. EPA, Recommendations from the EPA Groundwater
3.2.4.2 Discussion—AFFF concentrate is routinely shipped
Task Force, EPA 500-R-07-001, December 2007
and stored in 5-gallon poly drums known as carboys.
U.S. EPA, Handbook on the Management of Munitions
3.2.5 emerging chemicals of environmental concern, n—as
Response Actions. EPA 505-B-01-001. May 2005
defined in DoDI 4715.18, chemicals relevant to the Department
U.S. EPA, Groundwater Issue: Best Practices for Environ-
of Defense (DOD) that are characterized by a perceived or real
mental Site Management: A Practical Guide for Applying
threat to human health or the environment and that have new or
Environmental Sequence Stratigraphy to Improve Con-
changing toxicity values or new or changing human health or
ceptual Site Models, EPA/600/R-17/293, 2017
environmental regulatory standards.
U.S. EPA, PFAS Strategic Roadmap: EPA’s Commitments
3.2.5.1 Discussion—These chemicals are defined as emerg-
to Action 2021-2024. USEPA, Washington, DC, EPA-100-
ing contaminants in Practice E1527.
K-21-002, October 2021. https://www.epa.gov/system/
3.2.6 hazardous substance, n—means that group of sub-
files/documents/2021-10/pfas-roadmap_final- 508.pdf
stances defined as hazardous under CERCLA 101(14), and that
U.S. EPA, Office of the Inspector General. Superfund Sites
appear at 40 CFR §302.
Deferred to RCRA-E1SFF8-11-0006-9100116. March
1999. 3.2.6.1 Discussion—Particular chemicals/compounds that
are not defined as hazardous substances under CERCLA may
be defined as hazardous substances under local, state, or Tribal
laws and regulations. The definition of hazardous substances
Available from United States Environmental Protection Agency (EPA), William
stated here only applies to CERCLA §101(14) and does not
Jefferson Clinton Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460,
http://www.epa.gov. apply to local, state, provincial, or Tribal definitions. The user
E3358 − 23a
must determine if the state or applicable regulatory authority’s sludge being present is determined by evidence of factors
definition or hazardous substance includes PFAS. associated with the pit, pond, or lagoon, including, but not
limited to, discolored water, distressed vegetation, or the
3.2.7 hazardous waste, n—any hazardous waste having the
presence of an obvious wastewater discharge.
characteristics identified under or listed pursuant to section
3001 of the Solid Waste Disposal Act (42 USC § 6901 et seq.)
3.2.14 RCRA generators, n—those persons or entities that
(but not including any waste the regulation of which under the
generate hazardous wastes, as defined and regulated by RCRA;
Solid Waste Disposal Act has been suspended by Act of
these entities have submitted Form 8700-12 to the EPA.
Congress) and so forth.
3.2.15 RCRA generators list, n—list kept by EPA of those
3.2.7.1 Discussion—Some state waste management pro-
persons or entities that have submitted EPA Form 8700-12 to
grams regulate additional solid wastes as hazardous waste.
the Agency.
3.2.8 landfill, n—a place, location, tract of land, area, or
3.2.16 RCRA TSD facilities, n—those facilities at which
premises used for the disposal of solid wastes as defined by
treatment, storage, or disposal, or a combination thereof, of
state solid waste regulations; the term is synonymous with the
hazardous wastes takes place, subject to regulation and per-
term solid waste disposal site and is also known as a garbage
mitting under RCRA or a delegated state’s hazardous waste
dump, trash dump, or similar term.
management program; these facilities have submitted EPA
3.2.8.1 Discussion—The user is cautioned that not all gar-
Form 8700-23 to the US EPA.
bage dumps and trash dumps have permits issued by either the
3.2.17 RCRA TSD facilities list, n—list kept by EPA of those
state or local regulatory agency.
facilities that have submitted Form 8700-23 to the Agency, on
3.2.9 National Contingency Plan (NCP), n—the National
which treatment, storage, or disposal, or a combination
Oil and Hazardous Substances Pollution Contingency Plan
thereof, of hazardous wastes takes place, as defined and
found at 40 CFR § 300, which is the EPA’s regulations for how
regulated by RCRA.
hazardous substances are to be cleaned up pursuant to CER-
CLA. 3.2.18 records of emergency release notifications (SARA§
304), n—Section 304 of EPCRA or Title III of SARA requires
3.2.10 NPDES permit, n—the National Pollutant Discharge
operators of facilities to notify their local emergency planning
Elimination System permit program, created in 1972 by the
committee (as defined in EPCRA) and state emergency re-
Clean Water Act (CWA), helps address water pollution by
sponse commission (as defined in EPCRA) of any release
regulating point sources that discharge pollutants to waters of
beyond the facility’s boundary of any reportable quantity of
the United States; the permit provides two levels of control:
any extremely hazardous substance.
technology-based limits and water quality-based limits (if
3.2.18.1 Discussion—Records of such notifications are “re-
technology-based limits are not sufficient to provide protection
cords of emergency release notifications” (SARA § 304) and
of the water body).
may be found in the ERNS database.
3.2.11 PFAS, n—a group of manufactured chemicals con-
sisting of polymeric chains of carbon bonded to fluorine atoms, 3.2.19 safety data sheet (SDS), n—printed material concern-
ing a hazardous substance which is prepared by chemical
usually with a polar functional group at the head.
3.2.11.1 Discussion—PFAS are fluorinated substances with manufacturers, importers, and employers for hazardous chemi-
cals pursuant to OSHA’s Hazard Communication Standard, 29
a carbon chain structure. In perfluoroalkyl substances, each
carbon atom in the chain is fully saturated with fluorine CFR 1910.1200.
(carbon-fluorine bonds only), whereas the carbon chain in
3.2.20 solid waste disposal site, n—a place, location, tract of
polyfluoroalkyl substances is mostly saturated with fluorine
land, area, or premises used for the disposal of solid wastes as
(carbon-fluorine bonds), but also contains carbon- hydrogen
defined by state solid waste regulations.
bonds. The non-polymers are also based on chains of carbon
3.2.20.1 Discussion—Solid waste disposal site is synony-
atoms, usually with a chain length between 2 and 13 atoms,
mous with the term landfill and is also known as a garbage
much shorter than those of polymers. These non-polymers can
dump, trash dump, or similar term.
be split into a further 3 groups. The basic structure of these
3.2.21 solvent, n—a chemical compound that is capable of
groups are the same, being primarily made up of carbon and
dissolving another substance and a hazardous substance, used
fluorine in a repeating pattern, but the difference is that each
in a number of manufacturing/industrial processes including
group has another chemical group added (either a carboxylic
but not limited to dry cleaning, the manufacture of paints and
acid, a sulfonic acid or an alcohol). The shorter chain means,
coatings for industrial and household purposes, equipment
compared to polymers, they are more mobile, reactive and
clean-up, and surface degreasing in industrial settings.
more easily transferred into wildlife and humans.
3.2.22 state registered USTs, n—state lists of underground
3.2.12 Phase I Environmental Site Assessment, n—the pro-
storage tanks required to be registered under Subtitle I, Section
cess described in Practice E1527 and Practice E2247.
9002 of RCRA.
3.2.13 pits, ponds, or lagoons, n—man-made or natural
3.2.23 subject property, n—the real property that is the
depressions in a ground surface that are likely to hold liquids
subject of the records review, site visit, and initial site
or sludge containing hazardous substances or petroleum prod-
ucts. assessment described in this guide.
3.2.13.1 Discussion—The likelihood of such liquids or 3.2.23.1 Discussion—Real property includes buildings and
E3358 − 23a
other fixtures and improvements located on the property and property; aerial photographs are commonly available from
affixed to the land. E1527 government agencies or private collections unique to a local
area.
3.2.24 sump, n—a pit, cesspool, or similar receptacle where
3.3.1.1 Discussion—Digital imagery from satellites, while
liquids drain, collect, or are stored.
not technically aerial photographs, may also be used to
3.2.25 Superfund Enterprise Management System (SEMS),
identify land uses and development activities of real property.
n—SEMS is the official repository for site and non-site- specific
3.3.2 disposal, v—the discharge, deposit, injection,
Superfund data in support of the Comprehensive Environmen-
dumping, spilling, leaking, or placing of any hazardous
tal Response, Compensation, and Liability Act; it contains
substances, or petroleum products or their derivatives into or
information on hazardous waste site assessment and remedia-
on any land or water so that such hazardous substances,
tion from 1983 to the present.
petroleum products or their derivatives, or any constituent
3.2.26 technical policy decision (TPD), n—the choices spe-
thereof may enter the environment or be emitted into the air or
cific to the User that are necessary to implement the risk- based discharged into any waters including ground water.
corrective action framework described in Guides E2081 and
3.3.3 environmental investigation, n—any investigation in-
E2205, or any replacement standards thereto, at a particular
tended to determine the nature and extent of environmental
site.
contamination or to determine the environmental condition of
3.2.26.1 Discussion—Examples of technical policy deci-
property.
sions are: data quality objectives, target risk levels, land use,
3.3.3.1 Discussion—Environmental investigations may
reasonably anticipated future use, ground water use, natural
include, but are not limited to, environmental site assessments,
resource protection, relevant ecological receptors and habitats,
preliminary assessments, site inspections, remedial
stakeholder notification and involvement, exposure factors, and
investigations, RCRA facility assessments, and RCRA facility
cultural resource protection.
investigations.
3.3.4 fill dirt, n—dirt, soil, sand, or other earth taken from a
3.2.27 toxics release inventory (TRI), n—the Toxics Release
different location, that is used to fill holes or depressions, create
Inventory is a publicly available database containing informa-
tion on toxic chemical releases and other waste management mounds, or otherwise artificially change the grade or elevation
of real property.
activities in the United States.
3.3.4.1 Discussion—Fill dirt does not include material that
3.2.28 underground storage tank (UST), n—any tank, in-
is used in limited quantities for normal landscaping activities.
cluding underground piping connected to the tank that is or has
3.3.4.2 Discussion—The potential for fill dirt to be contami-
been used to contain hazardous substances or petroleum
nated with hazardous substances should be considered, and if
products and the volume of which is 10 % or more beneath the
appropriate, the material should be tested and analyzed for
surface of the ground.
chemicals of concern.
3.2.29 USGS 7.5 minute topographic map, n—the term
3.3.5 migration, v—the movement of contaminant(s) away
“USGS topographic map” refers to maps that covers a quad-
from a source through permeable subsurface media (such as the
rangle that measures 7.5 minutes of longitude and latitude on
movement of a ground water plume of contamination), or
all sides, so these are also referred to as 7.5-minute maps,
movement of contaminant(s) by a combination of surficial and
quadrangle maps, or “quad” maps with a wide range of scales,
subsurface processes.
but the scale used for all modern USGS topographic maps is
3.3.5.1 Discussion—Vapor intrusion is an example of mi-
1:24,000.
gration.
3.2.30 wastewater, n—water that (1) means any water
3.3.6 NACE, n—the statistical classification of economic
which, during manufacturing or processing, comes into direct
activities in the European Community.
contact with or results from the production or use of any raw
3.3.6.1 Discussion—NACE (Nomenclature des Activités
material, intermediate product, finished product, byproduct, or
Économiques dans la Communauté Européenne) is a European
waste product or (2) conveys or has conveyed sewage.
industry standard classification system similar in function to
3.2.30.1 Discussion—Wastewater does not include water Standard Industry Classification (SIC) and North American
originating on or passing through or adjacent to a site, such as Industry Classification System (NAICS) for classifying busi-
stormwater flows, that has not been used in industrial or ness activities.
manufacturing processes, has not been combined with sewage,
3.3.7 North American Industry Classification System or
or is not directly related to manufacturing, processing, or raw
NAICS, n—a classification of business establishments by type
materials storage areas at an industrial plant. Wastewater also
of economic activity.
includes washdown water that flows into drains that co-mingle
3.3.7.1 Discussion—The North American Industry Classifi-
and are discharged to a sewage system, leach field, collection
cation System is used by governments and businesses in
pond, or wastewater treatment plant.
Canada, Mexico, and the United States of America.
3.3 Definitions of Terms Specific to This Standard:
3.3.8 physical setting sources, n—sources that provide in-
3.3.1 aerial photographs, n—photographs, taken from an formation about the geologic, hydrogeologic, hydrologic, or
topographic characteristics of a property.
aerial platform, having sufficient resolution to allow identifi-
cation of development and activities of areas encompassing the 3.3.8.1 Discussion—Examples of physical setting sources
E3358 − 23a
include: U.S. Geological Survey 7.5-minute topographic maps, 3.3.15 storage, v—the containment of hazardous
geological survey maps produced by state or local agencies, substances, petroleum products or their derivatives, either on a
soil surveys produced by federal, state, and local government temporary basis or for a period of years, in such a manner as
agencies. not to constitute disposal of such hazardous substances,
petroleum products, or their derivatives.
3.3.9 preliminary assesment (PA), n—review of existing
3.3.15.1 Discussion—Storage of RCRA-regulated waste for
information and an off-site reconnaissance, if appropriate to
a period that exceeds 90-days may require a permit issued by
determine if a release or potential release may require addi-
the EPA or a state with delegated authority to enforce RCRA
tional investigation or action.
regulations.
3.3.9.1 Discussion—The term preliminary assessment as
3.3.16 user, n—the party seeking to use this guide to screen
defined in this document is significantly different from the
and characterize the property for the purpose of confirming
definition of the term in CERCLA guidance documents. A
past or present uses of PFAS at the property and to confirm
preliminary assessment may include an on-site reconnaissance,
releases of PFAS to the environment.
if appropriate.
3.3.17 visual and/or physical inspection, v—actions taken
3.3.10 release, v—any spilling, leaking, pumping, pouring,
during a preliminary investigation to include observations
emitting, emptying, discharging, injecting, escaping, leaching,
made by vision while walking through or otherwise traversing
dumping, or disposing into the environment (including the
a property and structures located on it and observations made
abandonment or discarding of barrels, containers, and other
by the sense of smell, particularly observations of sweet,
closed receptacles) of any hazardous chemical, extremely
aromatic, noxious or foul odors.
hazardous substance, or CERCLA hazardous substance.
3.4 Acronyms Abbreviations, and Initialisms:
3.3.11 remedial actions, n—as defined in CERCLA
3.4.1 AFFF—aqueous film-forming foam
§101(22), those actions consistent with a permanent remedy
taken instead of, or in addition to, removal action in the event
3.4.2 ATSDR—Agency for Toxic Substances and Disease
of a release or threatened release of a hazardous substance into
Registry
the environment, to prevent or minimize the release of haz-
3.4.3 ARARs—applicable or relevant and appropriate re-
ardous substances so that they do not migrate to cause
quirements
substantial danger to present or future public health or welfare
3.4.4 CERCLA—Comprehensive Environmental Response,
or the environment.
Compensation and Liability Act of 1980, as amended (42 USC
3.3.12 removal, v—the cleanup or removal of released
9620 et seq.)
hazardous substances from the environment; such actions as
3.4.5 CFR—Code of Federal Regulations
may be necessary to take in the event of the threat of release of
hazardous substances into the environment; such actions as
3.4.6 CSM—conceptual site model
may be necessary to monitor, assess, and evaluate the release
3.4.7 DoD—Department of Defense
or the threat of release of hazardous substances; the disposal of
3.4.8 EPA—United States Environmental Protection Agency
removed material; or the taking of such other actions as may be
necessary to prevent, minimize, or mitigate damage to the
3.4.9 EPCRA—Emergency Planning and Community Right
public health or welfare or to the environment, which may to Know Act, 42 USC
otherwise result from a release or threat of release.
3.4.10 ERNS—emergency response notification system
3.3.12.1 Discussion—The term includes, in addition, with-
3.4.11 ESA—environmental site assessment
out being limited to, security fencing or other measures to limit
3.4.12 GOCO—government-owned/contractor operated
access, provision of alternative water supplies, temporary
evacuation and housing of threatened individuals not otherwise
3.4.13 LUST—leaking underground storage tank
provided for, action taken under section 104(b) of CERCLA,
3.4.14 NACE—European Classification of Economic Ac-
post-removal site control, where appropriate, and any emer-
tivities
gency assistance which may be provided under the Disaster
3.4.15 NAICS—North American Industrial Classification
Relief Act of 1974.
System
3.3.13 site inspection (SI), n—a systematic examination to
3.4.16 NCP—National Contingency Plan (40 CFR Part
determine whether there is a release or potential release and
300)
the nature of the associated threats.
3.3.13.1 Discussion—The purpose of the site inspection is
3.4.17 NPDES—National Pollutant Discharge Elimination
to augment the data collected in the preliminary assessment System
and to generate, if necessary, sampling and other field data to
3.4.18 OB/OD—open burning/open detonation
determine if further action or investigation is appropriate.
3.4.19 PA—preliminary assessment
3.3.14 standard industrial classification, n—the Standard
3.4.20 PFAS—perfluoroalkyl and polyfluoroalkyl sub-
Industrial Classification is a system for classifying industries
stances
by a four-digit code; established in the United States in 1937,
it is used by government agencies to classify industry areas. 3.4.21 POTW—publicaly-owned treatment works
E3358 − 23a
3.4.22 RCRA—Resource Conservation and Recovery Act, 3.4.35 WWTP—wastewater treatment tank
as amended, 42 USC 6901 et seq.
4. Significance and Use
3.4.23 SARA—Superfund Amendments and Reauthorization
Act of 1986
4.1 PFAS are widely used in commercial and industrial
3.4.24 SDS—Safety Data Sheet
applications worldwide (see Fig. 1). PFAS are of concern due
to their documented persistence and their studied impacts on
3.4.25 SEMS—Superfund Enterprise Management System
human health and the environmental. While there is no
3.4.26 SI—site inspection
comprehensive source of information on the many individual
3.4.27 SIC—Standard Industrial Classification
PFAS substances and their functions in different applications, a
3.4.28 TPD—technical policy decision
range of resources are available to the practitioner. This guide
provides information to assist the practitioner in navigating
3.4.29 TRI—toxic release inventory
these challenges during the initial screening and site charac-
3.4.30 TSDF—treatment, storage, and disposal facility
terization process.
3.4.31 UFP-QAPP—Uniform Federal Policy for Quality
4.2 The user should note that PFAS regulatory management
Assurance Project Plans
framework at the federal and state level are evolving quickly.
3.4.32 USC—United States Code
Therefore, consultation with legal and technical representatives
3.4.33 USGS—United States Geological Survey
with knowledge of federal, state, and local PFAS regulations is
3.4.34 UST—underground storage tank advised prior to use of this guide. Environmental audit policies
FIG. 1 Activity/Industry that may be Sources of PFAS Use and Release
Source: AEI Consultants
E3358 − 23a
or privileges may be applicable to some of the steps described ment of PFAS, including air emissions, wastewater discharges,
in this guide (see EPA, 2000). biosolids, groundwater, surface water, and impacted soil are
rapidly evolving and may include additional reporting require-
4.3 Multi-step Risk Management Framework:
ments. (4)
4.3.1 The actions described in this guide are intended to
provide a multi-step risk management framework to confirm,
4.5 PFAs Use and Occurence:
with reasonable certainty, that PFAS may have been used at a
4.5.1 PFAS containing chemicals have been used in a broad
federally-owned, publicly-owned, or privately-owned property.
spectrum of federal and commercial activities, as illustrated in
This standard provides guidance on how to focus limited
Fig. 1. The use of PFAS as a component of AFFF for
resources on using a multi-step process, illustrated in Fig. 2, to
firefighting at military installations, refineries, petrochemical
identify property potentially impacted by on-site or off-site
manufacturing facilities, tank farms, and airports is well
uses and releases of PFAS. Section 4.5 describes the use and
known. PFAS are used as coatings for fabric and paper products
occurrence of PFAS. Section 4.6 describes activities at govern-
to repel water and grease (see ITRC’s PFAS Technical Guide).
ment and federal installations where PFAS use is expected.
PFAS have also been components of vapor control mists for
Section 4.7 broadly outlines the industry sectors where the use
electroplating operations. Other industrial uses of PFAS are
of PFAS has been documented (Glüge, 2020 (2), Gaines, 2022
described in this section as well.
(3)).
4.6 Government and Military Installations Use of PFAs:
4.4 PFAs History and Use:
4.6.1 PFAS have been used in a variety of applications at
4.4.1 In the 1940s, industrial processes to commercially
government/military facilities, including as a component in
produce PFAS were first developed. Since then, PFAS have
AFFF, which was routinely used at fire-fighting training areas
been used to make many industrial and consumer products
and equipment test areas and is still used at crash sites and
worldwide. Since the 1950s, PFAS have been widely used in
surface treatment applications for paper, fabric, cookware and some fire suppression systems in hangars. In addition, PFAS
has been a component of mist-suppression compounds associ-
carpeting which allows these products and materials to repel
oil, water, and stains. In the 1960s, the United States Navy used ated with electroplating operations at federal facilities and
PFAS to develop Aqueous Film Forming Foam products for government-owned, contractor-operated (GOCO) research and
firefighting applications and the technology was patented by development plants. The wastewater treatment plants (WWTP)
the U.S. Navy. Since the 1960s, the U.S. Food and Drug at federal installations may release PFAS as emissions and may
Administration (FDA) has authorized several broad classes of
discharge PFAS into receiving waters as effluent. The biosolids
PFAS for use in food contact substances due to their non-stick produced by the WWTP may contain PFAS if PFAS were
and grease, oil, and water-resistant properties. Over the past 50
present in the influent.
years, PFAS use has expanded in food and consumer products
4.6.2 Current and historical AFFFstorage and transfer areas
manufacturing and packaging and industrial operations and
at federally-owned facilities are of potential concern for
applications worldwide. Restrictions or prohibitions on the use
release to the environment. Historical reports of uncontrolled
of PFAS in food and consumer products have been enacted at
spills and the repeated use of AFFF during fire training and
the State and local level.
firefighting have been correlated with higher concentrations of
4.4.2 Release of PFAS during manufacture into the atmo-
PFAS in surface water and groundwater. Discharges of liquids
sphere may have occurred, and may be continuing to occur,
from fire-fighting practices into stormwater and sewer systems
followed by subsequent redeposition of PFAS materials on land
and holding ponds are potential source areas. In addition,
where PFAS can enter surface water and groundwater. Other
treated effluents from remediation of other hazardous sub-
potential sources of PFAS emissions are dry cleaning and
stances at the installation should be considered potential source
commercial laundry operations where clothing coated with
areas.
PFAS-containing materials is cleaned or laundered. Emissions
4.6.2.1 Accordingly, key elements for identifying signifi-
from these sources may include particulate matter such as lint.
cant PFAS sources at federally-owned facilities are the storage
Additionally, PFAS may be or have been discharged without
and use of AFFF. PFAS from AFFF used in firefighting and fire
treatment to wastewater treatment plants or landfills, and
suppression systems are considered to have the greatest poten-
eventually be released into the environment by treatment
tial for release of PFAS to the environment in terms of mass
systems that are not designed to mitigate PFAS. Industrial
concentration at government/military installations.
discharges of PFAS were unregulated for many years; however,
4.6.2.2 Other potential sources of PFAS to the environment
change is underway in the U.S. at both the state and federal
include historical on-site land disposal areas/landfills contain-
level as well as internationally.
ing operations wastes (for example, from electroplating),
4.4.3 Broadly, consumer and industrial uses of PFAS-
wastewater treatment sludges and effluents, or PFAS materials
containing products and waste may releasePFAS into landfills
themselves. Landfill leachate could carry PFAS to groundwater.
and landfill leachate, and into municipal wastewater, where it
may accumulate undetected in biosolids which may be land 4.6.3 AFFF used in Fire-Fighting Exercises and Fire Sup-
pression are water-based (60-90%) and frequently contain
applied. PFAS may be subsequently used in soil amendments
used to grow animal feed and food crops and produce for hydrocarbon-based surfactants, such as sodium alkyl sulfate,
and fluorosurfactants, such as fluorotelomers, PFOA, and/or
human consumption. The user should be aware that federal,
tribal, state, and municipal regulations affecting the manage- PFOS. AFFF containing PFAS were developed in the early to
E3358 − 23a
FIG. 2 Initial Site Screening and Characterization Flow Diagram
E3358 − 23a
mid-1960s for use on Class B fires and were placed into routine 4.7.1.1 Chemical industry with a special focus on process-
use at government installations by the early1970s and are still ing aids in the polymerization of fluoropolymers,
in use today.
4.7.1.2 Surface protection of textile, apparel, leather,
4.6.3.1 Companies including 3M, DuPont, Ansul, and
carpets, and paper,
Chemguard were the primary fire-fighting foam producers that
4.7.1.3 Electronics industry (semiconductors and wire; NA-
used fluoro-chemical surfactants in the production of AFFF.
ICS 334400 and 335929, respectively) (Note: and solar
Typically, AFFF concentrate was proportionally mixed into
panels),
water lines using in-line eductors or other proportioning
4.7.1.4 Consumer and personal care products,
devices to create the necessary foam solution ranging from 3 %
4.7.1.5 Food processing and packaging,
to 6 % of the concentrate. As noted, AFFF was primarily used
4.7.1.6 Plastics and rubber production,
with Class B fuel fires because the chemical properties of PFAS
4.7.1.7 Pulp and paper industry,
in AFFF created a thick foam blanket. Class A fire-fighting
4.7.1.8 Coatings, paints, and varnishes,
foams were used to extinguish wood and grass fires and do not
4.7.1.9 Refinery and petrochemical industry,
contain PFAS.
4.7.1.10 Munitions and explosives production,
4.6.4 Open Burning / Open Detonation of Munitions—Open
4.7.1.11 Aircraft and heavy equipment manufacturing,
burning and open detonation of munitions are non-routine
4.7.1.12 Public-sector and private-sector airports, and
activities at some military installations and federal facilities.
4.7.1.13 Electroplating of parts and components.
The types of munitions that may contain PFAS are primarily
4.7.2 As noted in section 4.6.5, electroplating, specifically
limited to pyrotechnics (flares). The open- burning, open-
hard chromium plating, is an industrial activity where PFAS-
detonation of munitions is subject to Subpart X of the RCRA
containing mist suppressants may have been used. PFAS were
Permitting Process (see 40 CFR 264, Subpart X).
sometimes used during the chromium electroplating process as
NOTE 1—If the open detonation activities are conducted are part of the
a surfactant in chromic acid baths.
installation’s training program, they may not be subject to permitting
4.7.3 Chemical industry with a special focus on processing
under RCRA Subpart X. Temperatures in munitions deactivation furnaces
aids in the polymerization of fluoropolymers. Important uses of
and rotary kilns reach up to 1500°F, which may not be adequate to destroy
PFAS (EPA, 2005). Open burning may not achieve temperatures high
PFAS in the chemical industr
...

This document is not an ASTM standard and is intended only to provide the user of an ASTM standard an indication of what changes have been made to the previous version. Because
it may not be technically possible to adequately depict all changes accurately, ASTM recommends that users consult prior editions as appropriate. In all cases only the current version
of the standard as published by ASTM is to be considered the official document.
Designation: E3358 − 23 E3358 − 23a
Standard Guide for
Per- and Polyfluoroalkyl Substances Site Screening and
Initial Characterization
This standard is issued under the fixed designation E3358; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
INTRODUCTION
This guide discusses the key decision considerations and best practices for the screening and initial
characterization of sites to evaluate the potential release of per- and polyfluoroalkyl substances (PFAS)
into the environment. This guide provides a flexible, defensible framework applicable to a wide range
of environment programs. It is structured to support a tiered approach with procedures and techniques
of increasing complexity as the user proceeds through the site evaluation process to aid users in
achieving project objectives. There are numerous technical policy decisions that must be made in the
screening and initial characterization of sites. It is not the intent of this guide to define appropriate
technical policy decisions, but rather to provide technical support within existing decision frame-
works.
1. Scope
1.1 Per- and polyfluoroalkyl substances (PFAS) are a group of over 7,000 manmade compounds consisting of polymeric chains
of carbon bonded to fluorine atoms, usually with a polar functional group at the head. This guide recognizes that PFAS can be
categorized as polymeric or nonpolymeric, collectively amounting to more than 4,700 Chemical Abstracts Service (CAS)-
registered substances. Environmental concerns pertaining to PFAS are centered primarily on the perfluoroalkyl acids (PFAA), a
subclass of per-and polyfluoroalkyl substances, which display extreme persistence and chain-length dependent bioaccumulation
and adverse effects in biota.
1.2 The regulatory framework for PFAS continues to evolve, both domestically and internationally. The United States
Environmental Protection Agency (EPA) is proceeding with a wide-ranging set of PFAS regulatory actions (EPA, 2021). While the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) does not currently recognize PFAS as
hazardous substances, the statute does require actions to protect public health and the environment from contaminants and
pollutants released to the environment. Other federal regulatory programs, such as the Safe Drinking Water Act are being used to
address drinking water supplies adversely impacted by releases of PFAS. The Clean Water Act’s National Pollutant Discharge
Elimination System (NPDES) permitting program is tool that both federal and state regulators are using to regulate the inflows of
PFAS-impacted wastewaters at both publicly-owned treatment works (POTW) and federally-owned wastewater treatment plants
and the concentration of PFAS in permitted effluent. EPA continues to add additional per-and polyfluoroalkyl substances to the list
of substances reportable under the federal Toxic Release Inventory (TRI) reporting program. International efforts to address per-and
polyfluoroalkyl substances include Australia’s PFAS National Environmental Management Plan, Version 2 (2020), Canada’s
This guide is under the jurisdiction of ASTM Committee E50 on Environmental Assessment, Risk Management and Corrective Action and is the direct responsibility
of Subcommittee E50.04 on Corrective Action.
Current edition approved Feb. 1, 2023Aug. 1, 2023. Published May 2023August 2023. Originally approved in 2023. Last previous edition approved in 2023 as E3358–23.
DOI: 10.1520/E3358–2310.1520/E3358–23A
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E3358 − 23a
Prohibition of Certain Toxic Substances Regulations, (2022), the Stockholm Convention on Persistent Organic Pollutants, and the
European Union’s Water Framework Directive (1).
1.3 Hazardous waste treatment, storage, and disposal facilities (TSDF) currently operating under the Resource Conservation and
Recovery Act (RCRA) via a Part B Permit may be ordered to investigate releases of PFAS under a RCRA Corrective Action order.
EPA made a policy decision in the 1990s to defer many potential CERCLA enforcement actions to the RCRA Corrective Action
Program (EPA, 1999). Permitted TSDFs at refineries may be subject to RCRA Corrective Action, as opposed to other regulatory
programs, to address the releases of PFAS associated past and current use of aqueous film-forming foam (AFFF).
1.4 Numerous states and Tribes are using their existing regulatory programs to direct investigation, site remediation, and
correction action related to releases of PFAS to soil, groundwater, and surface waters. These actions range from health advisories
and guidelines to enforceable regulatory standards. Regulatory considerations include PFAS risks to both human health and
ecological receptors that are protected under a broad array of federal, state, and tribal regulatory programs as well as by treaty
rights.
1.5 This guide assists users in the identification of real property concerns that may be the source of PFASreleases or that may be
adversely impacted by releases of PFAS. The goal of this guide is to assist managers of environmental risk in their resource
allocation decision-making.
1.6 This guide does not constitute “All Appropriate Inquiries” as defined in 40 CFR Part 312 and is not intended to provide the
user with any of the landowner liability protections codified in CERCLA §101(35)(A)(i), CERCLA §101(40)(B)(iii), or CERCLA
§107(q)(1)(A)(viii).
1.7 This guide describes widely accepted considerations and best practices used in the site screening and initial site
characterization process, with specific consideration of the potential for the release of PFAS into the environment. This guide
complements but does not replace existing technical guidance and regulatory requirements.
1.8 This guide does not address and is not applicable to sampling and analysis of public or private domestic water supply systems
subject to regulation under the Safe Drinking Water Act and state private well testing act requirements. Regulatory agencies
responsible for implementing the Safe Drinking Water Act may have established sampling and reporting requirements for public,
community, and privately operated water systems.
1.9 All references to specific federal or state programs are current as of the date of publication. The user is cautioned not to rely
on this guide alone but to consult directly with the appropriate program and legal counsel regarding this complex and rapidly
evolving concern.
1.10 This guide is intended to complement, not replace, existing regulatory requirements or guidance. ASTM International
(ASTM) guides are not regulations; they are consensus-based standards that may be followed as needed.
1.11 Units—The values stated in SI units are to be regarded as the standard. Other units, such as fractional units of parts per billion
(ppb) and parts per trillion (ppt), are also included in this guide.
1.12 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility
of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of
regulatory limitations prior to use.
1.13 This international standard was developed in accordance with internationally recognized principles on standardization
established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued
by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
2. Referenced Documents
2.1 ASTM Standards:
The boldface numbers in parentheses refer to the list of references at the end of this standard.
For referenced ASTM standards, visit the ASTM website, www.astm.org, or contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM Standards
volume information, refer to the standard’s Document Summary page on the ASTM website.
E3358 − 23a
D6008 Practice for Determining the Environmental Condition of Federal Property
D6235 Practice for Expedited Site Characterization of Vadose Zone and Groundwater Contamination at Hazardous Waste
Contaminated Sites
D7968 Test Method for Determination of Polyfluorinated Compounds in Soil by Liquid Chromatography Tandem Mass
Spectrometry (LC/MS/MS)
D7979 Test Method for Determination of Per- and Polyfluoroalkyl Substances in Water, Sludge, Influent, Effluent, and
Wastewater by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)
D8421 Test Method for Determination of Per- and Polyfluoroalkyl Substances (PFAS) in Aqueous Matrices by Co-solvation
followed by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)
E29 Practice for Using Significant Digits in Test Data to Determine Conformance with Specifications
E1527 Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process
E1689 Guide for Developing Conceptual Site Models for Contaminated Sites
E1903 Practice for Environmental Site Assessments: Phase II Environmental Site Assessment Process
E2020 Guide for Data and Information Options for Conducting an Ecological Risk Assessment at Contaminated Sites
E2081 Guide for Risk-Based Corrective Action
E2173 Guide for Disclosure of Environmental Liabilities
E2205 Guide for Risk-Based Corrective Action for Protection of Ecological Resources
E2247 Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural
Property
E3123 Guide for Recognition and Derecognition of Environmental Liabilities
E3274 Guide for Management of Investigation-Derived Waste Associated with PFAS
E3302 Guide for PFAS Analytical Methods Selection
2.2 Other Referenced Documetns:
Agency for Toxic Substances and Disease Registry, Toxicological Profile for Perfluoroalkyls, May 2021
California Office of Environmental Health Hazard Assessment, Toxicity Criteria Database, https://data.ca.gov/dataset/toxicity-
criteria-database, May 2019
California Department of Toxic Substances Control, Preliminary Endangerment Assessment Manual, 2015
CRC CARE 2018, Technical Report 43, Practitioner guide to risk-based assessment, remediation and management of PFAS site
contamination
Department of Defense Instruction 4715.18, Emerging Chemicals (ECs) of Environmental Concern, September 4, 2019
ISO 21365:2019 Soil quality — Conceptual site models for potentially contaminated sites
OECD, Lists of PFOS, PFAS, PFOA, PFCA Related Compounds and Chemicals that may Degrade to PFCA. Environment,
Health and Safety Publications Series on Risk Management No. 21, ENV/JM/MONO (2006, rev. 2007)15, 157 pp.
Pubchem Databases, pubchem.ncbi.nlm.nih.gov
2.3 USEPA References and Databases:
Envirofacts (https://enviro.epa.gov/): A single point of access to select U.S. EPA environmental data. This website provides
access to several EPA databases to provide the user with information about environmental activities that may affect air, water,
and land anywhere in the United States
Superfund Enterprise Management System (https://www.epa.gov/enviro/sems-search)
FEDFacts (https://www.epa.gov/fedfac): Information about the Federal Electronic Docket Facilities regarding contaminated
federal facility sites in specific communities, technical fact sheets and tools and resources to help government agencies and
their contractors fulfill cleanup obligations
U.S. EPA, Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations; Notice, 65 FR 19618,
April 11, 2000
U.S. EPA, Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G-4, EPA/240/B-06-01, 2006
U.S. EPA, Comptox Dashboard: https://comptox.epa.gov/dashboard
U.S. EPA, ECOTOX database; https://cfpub.epa.gov/ecotox/index.cfm
U.S. EPA, Health and Environmental Research Online (HERO) https;//hero.epa.gov/hero
U.S. EPA, Recommendations from the EPA Groundwater Task Force, EPA 500-R-07-001, December 2007
U.S. EPA, Handbook on the Management of Munitions Response Actions. EPA 505-B-01-001. May 2005
U.S. EPA, Groundwater Issue: Best Practices for Environmental Site Management: A Practical Guide for Applying
Environmental Sequence Stratigraphy to Improve Conceptual Site Models, EPA/600/R-17/293, 2017
U.S. EPA, PFAS Strategic Roadmap: EPA’s Commitments to Action 2021-2024. USEPA, Washington, DC, EPA-100-K-21-002,
October 2021. https://www.epa.gov/system/files/documents/2021-10/pfas-roadmap_final- 508.pdf
U.S. EPA, Office of the Inspector General. Superfund Sites Deferred to RCRA-E1SFF8-11-0006-9100116. March 1999.
Available from United States Environmental Protection Agency (EPA), William Jefferson Clinton Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460,
http://www.epa.gov.
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3. Terminology
3.1 This section provides definitions of terms not unique to this practice, descriptions of terms specific to this practice, and a list
of acronyms and abbreviations used herein. The terms are an integral part of this guide and are critical to its understanding and
use.
3.2 Definitions:
3.2.1 aqueous film forming foam (AFFF), n—a fire suppressant used to extinguish flammable liquid fires such as fuel fires.
3.2.1.1 Discussion—
Aqueous film forming foam is often used in shipboard and shore facility fire suppression systems, fire fighting vehicles, and at fire
training facilities. AFFF may be used to prevent fires at sites where alcohol-based products are potential fuel sources. Industrial
facilities, such as refineries and petroleum terminals, with large quantities of flammable and combustible liquids in storage often
use AFFF in the facility’s fire suppression system.
3.2.2 conceptual site model, n—for the purpose of this guide, a written or pictorial representation of an environmental system and
the biological, physical, and chemical processes that determine the transport of contaminants from sources through environmental
media to human and ecological receptors within the system (see Guide E1689.)
3.2.3 contaminated public wells, n—public wells used for drinking water that have been designated by a government entity as
contaminated by toxic substances (for example, chlorinated solvents), or as having water unsafe to drink without treatment.
3.2.4 drum, n—as defined by the U.S. Department of Transportation, is a flat-ended or convex-ended cylindrical packaging made
of metal, fiberboard, plastic, plywood, or other suitable materials; this definition does not include cylinders, jerricans, wooden
barrels or bulk packagings.
3.2.4.1 Discussion—
At federal facilities, a metal or plastic container (typically, but not necessarily, holding 55 gal [208 L] of liquid) that may have been
used to store hazardous substances or petroleum products.
3.2.4.2 Discussion—
AFFF concentrate is routinely shipped and stored in 5-gallon poly drums known as carboys.
3.2.5 emerging chemicals of environmental concern, n—as defined in DoDI 4715.18, chemicals relevant to the Department of
Defense (DOD) that are characterized by a perceived or real threat to human health or the environment and that have new or
changing toxicity values or new or changing human health or environmental regulatory standards.
3.2.5.1 Discussion—
These chemicals are defined as emerging contaminants in Practice E1527.
3.2.6 hazardous substance, n—means that group of substances defined as hazardous under CERCLA 101(14), and that appear at
40 CFR §302.
3.2.6.1 Discussion—
Particular chemicals/compounds that are not defined as hazardous substances under CERCLA may be defined as hazardous
substances under local, state, or Tribal laws and regulations. The definition of hazardous substances stated here only applies to
CERCLA §101(14) and does not apply to local, state, provincial, or Tribal definitions. The user must determine if the state or
applicable regulatory authority’s definition or hazardous substance includes PFAS.
3.2.7 hazardous waste, n—any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of
the Solid Waste Disposal Act (42 USC § 6901 et seq.) (but not including any waste the regulation of which under the Solid Waste
Disposal Act has been suspended by Act of Congress) and so forth.
3.2.7.1 Discussion—
Some state waste management programs regulate additional solid wastes as hazardous waste.
3.2.8 landfill, n—a place, location, tract of land, area, or premises used for the disposal of solid wastes as defined by state solid
waste regulations; the term is synonymous with the term solid waste disposal site and is also known as a garbage dump, trash
dump, or similar term.
3.2.8.1 Discussion—
The user is cautioned that not all garbage dumps and trash dumps have permits issued by either the state or local regulatory agency.
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3.2.9 National Contingency Plan (NCP), n—the National Oil and Hazardous Substances Pollution Contingency Plan found at 40
CFR § 300, which is the EPA’s regulations for how hazardous substances are to be cleaned up pursuant to CERCLA.
3.2.10 NPDES permit, n—the National Pollutant Discharge Elimination System permit program, created in 1972 by the Clean
Water Act (CWA), helps address water pollution by regulating point sources that discharge pollutants to waters of the United States;
the permit provides two levels of control: technology-based limits and water quality-based limits (if technology-based limits are
not sufficient to provide protection of the water body).
3.2.11 PFAS, n—a group of manufactured chemicals consisting of polymeric chains of carbon bonded to fluorine atoms, usually
with a polar functional group at the head.
3.2.11.1 Discussion—
PFAS are fluorinated substances with a carbon chain structure. In perfluoroalkyl substances, each carbon atom in the chain is fully
saturated with fluorine (carbon-fluorine bonds only), whereas the carbon chain in polyfluoroalkyl substances is mostly saturated
with fluorine (carbon-fluorine bonds), but also contains carbon- hydrogen bonds. The non-polymers are also based on chains of
carbon atoms, usually with a chain length between 2 and 13 atoms, much shorter than those of polymers. These non-polymers can
be split into a further 3 groups. The basic structure of these groups are the same, being primarily made up of carbon and fluorine
in a repeating pattern, but the difference is that each group has another chemical group added (either a carboxylic acid, a sulfonic
acid or an alcohol). The shorter chain means, compared to polymers, they are more mobile, reactive and more easily transferred
into wildlife and humans.
3.2.12 Phase I Environmental Site Assessment, n—the process described in Practice E1527 and Practice E2247.
3.2.13 pits, ponds, or lagoons, n—man-made or natural depressions in a ground surface that are likely to hold liquids or sludge
containing hazardous substances or petroleum products.
3.2.13.1 Discussion—
The likelihood of such liquids or sludge being present is determined by evidence of factors associated with the pit, pond, or lagoon,
including, but not limited to, discolored water, distressed vegetation, or the presence of an obvious wastewater discharge.
3.2.14 RCRA generators, n—those persons or entities that generate hazardous wastes, as defined and regulated by RCRA; these
entities have submitted Form 8700-12 to the EPA.
3.2.15 RCRA generators list, n—list kept by EPA of those persons or entities that have submitted EPA Form 8700-12 to the
Agency.
3.2.16 RCRA TSD facilities, n—those facilities at which treatment, storage, or disposal, or a combination thereof, of hazardous
wastes takes place, subject to regulation and permitting under RCRA or a delegated state’s hazardous waste management program;
these facilities have submitted EPA Form 8700-23 to the US EPA.
3.2.17 RCRA TSD facilities list, n—list kept by EPA of those facilities that have submitted Form 8700-23 to the Agency, on which
treatment, storage, or disposal, or a combination thereof, of hazardous wastes takes place, as defined and regulated by RCRA.
3.2.18 records of emergency release notifications (SARA§ 304), n—Section 304 of EPCRA or Title III of SARA requires operators
of facilities to notify their local emergency planning committee (as defined in EPCRA) and state emergency response commission
(as defined in EPCRA) of any release beyond the facility’s boundary of any reportable quantity of any extremely hazardous
substance.
3.2.18.1 Discussion—
Records of such notifications are “records of emergency release notifications” (SARA § 304) and may be found in the ERNS
database.
3.2.19 safety data sheet (SDS), n—printed material concerning a hazardous substance which is prepared by chemical
manufacturers, importers, and employers for hazardous chemicals pursuant to OSHA’s Hazard Communication Standard, 29 CFR
1910.1200.
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3.2.20 solid waste disposal site, n—a place, location, tract of land, area, or premises used for the disposal of solid wastes as defined
by state solid waste regulations.
3.2.20.1 Discussion—
Solid waste disposal site is synonymous with the term landfill and is also known as a garbage dump, trash dump, or similar term.
3.2.21 solvent, n—a chemical compound that is capable of dissolving another substance and a hazardous substance, used in a
number of manufacturing/industrial processes including but not limited to dry cleaning, the manufacture of paints and coatings for
industrial and household purposes, equipment clean-up, and surface degreasing in industrial settings.
3.2.22 state registered USTs, n—state lists of underground storage tanks required to be registered under Subtitle I, Section 9002
of RCRA.
3.2.23 subject property, n—the real property that is the subject of the records review, site visit, and initial site assessment described
in this guide.
3.2.23.1 Discussion—
Real property includes buildings and other fixtures and improvements located on the property and affixed to the land. E1527
3.2.24 sump, n—a pit, cesspool, or similar receptacle where liquids drain, collect, or are stored.
3.2.25 Superfund Enterprise Management System (SEMS), n—SEMS is the official repository for site and non-site- specific
Superfund data in support of the Comprehensive Environmental Response, Compensation, and Liability Act; it contains
information on hazardous waste site assessment and remediation from 1983 to the present.
3.2.26 technical policy decision (TPD), n—the choices specific to the User that are necessary to implement the risk- based
corrective action framework described in Guides E2081 and E2205, or any replacement standards thereto, at a particular site.
3.2.26.1 Discussion—
Examples of technical policy decisions are: data quality objectives, target risk levels, land use, reasonably anticipated future use,
ground water use, natural resource protection, relevant ecological receptors and habitats, stakeholder notification and involvement,
exposure factors, and cultural resource protection.
3.2.27 toxics release inventory (TRI), n—the Toxics Release Inventory is a publicly available database containing information on
toxic chemical releases and other waste management activities in the United States.
3.2.28 underground storage tank (UST), n—any tank, including underground piping connected to the tank that is or has been used
to contain hazardous substances or petroleum products and the volume of which is 10 % or more beneath the surface of the ground.
3.2.29 USGS 7.5 minute topographic map, n—the term “USGS topographic map” refers to maps that covers a quadrangle that
measures 7.5 minutes of longitude and latitude on all sides, so these are also referred to as 7.5-minute maps, quadrangle maps, or
“quad” maps with a wide range of scales, but the scale used for all modern USGS topographic maps is 1:24,000.
3.2.30 wastewater, n—water that (1) means any water which, during manufacturing or processing, comes into direct contact with
or results from the production or use of any raw material, intermediate product, finished product, byproduct, or waste product or
(2) conveys or has conveyed sewage.
3.2.30.1 Discussion—
Wastewater does not include water originating on or passing through or adjacent to a site, such as stormwater flows, that has not
been used in industrial or manufacturing processes, has not been combined with sewage, or is not directly related to manufacturing,
processing, or raw materials storage areas at an industrial plant. Wastewater also includes washdown water that flows into drains
that co-mingle and are discharged to a sewage system, leach field, collection pond, or wastewater treatment plant.
3.3 Definitions of Terms Specific to This Standard:
3.3.1 aerial photographs, n—photographs, taken from an aerial platform, having sufficient resolution to allow identification of
development and activities of areas encompassing the property; aerial photographs are commonly available from government
agencies or private collections unique to a local area.
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3.3.1.1 Discussion—
Digital imagery from satellites, while not technically aerial photographs, may also be used to identify land uses and development
activities of real property.
3.3.2 disposal, v—the discharge, deposit, injection, dumping, spilling, leaking, or placing of any hazardous substances, or
petroleum products or their derivatives into or on any land or water so that such hazardous substances, petroleum products or their
derivatives, or any constituent thereof may enter the environment or be emitted into the air or discharged into any waters including
ground water.
3.3.3 environmental investigation, n—any investigation intended to determine the nature and extent of environmental contami-
nation or to determine the environmental condition of property.
3.3.3.1 Discussion—
Environmental investigations may include, but are not limited to, environmental site assessments, preliminary assessments, site
inspections, remedial investigations, RCRA facility assessments, and RCRA facility investigations.
3.3.4 fill dirt, n—dirt, soil, sand, or other earth taken from a different location, that is used to fill holes or depressions, create
mounds, or otherwise artificially change the grade or elevation of real property.
3.3.4.1 Discussion—
Fill dirt does not include material that is used in limited quantities for normal landscaping activities.
3.3.4.2 Discussion—
The potential for fill dirt to be contaminated with hazardous substances should be considered, and if appropriate, the material
should be tested and analyzed for chemicals of concern.
3.3.5 migration, v—the movement of contaminant(s) away from a source through permeable subsurface media (such as the
movement of a ground water plume of contamination), or movement of contaminant(s) by a combination of surficial and
subsurface processes.
3.3.5.1 Discussion—
Vapor intrusion is an example of migration.
3.3.6 NACE, n—the statistical classification of economic activities in the European Community.
3.3.6.1 Discussion—
NACE (Nomenclature des Activités Économiques dans la Communauté Européenne) is a European industry standard classification
system similar in function to Standard Industry Classification (SIC) and North American Industry Classification System (NAICS)
for classifying business activities.
3.3.7 North American Industry Classification System or NAICS, n—a classification of business establishments by type of economic
activity.
3.3.7.1 Discussion—
The North American Industry Classification System is used by governments and businesses in Canada, Mexico, and the United
States of America.
3.3.8 physical setting sources, n—sources that provide information about the geologic, hydrogeologic, hydrologic, or topographic
characteristics of a property.
3.3.8.1 Discussion—
Examples of physical setting sources include: U.S. Geological Survey 7.5-minute topographic maps, geological survey maps
produced by state or local agencies, soil surveys produced by federal, state, and local government agencies.
3.3.9 preliminary assesment (PA), n—review of existing information and an off-site reconnaissance, if appropriate to determine if
a release or potential release may require additional investigation or action.
3.3.9.1 Discussion—
The term preliminary assessment as defined in this document is significantly different from the definition of the term in CERCLA
guidance documents. A preliminary assessment may include an on-site reconnaissance, if appropriate.
3.3.10 release, v—any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching,
dumping, or disposing into the environment (including the abandonment or discarding of barrels, containers, and other closed
receptacles) of any hazardous chemical, extremely hazardous substance, or CERCLAhazardous substance.
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3.3.11 remedial actions, n—as defined in CERCLA §101(22), those actions consistent with a permanent remedy taken instead of,
or in addition to, removal action in the event of a release or threatened release of a hazardous substance into the environment, to
prevent or minimize the release of hazardous substances so that they do not migrate to cause substantial danger to present or future
public health or welfare or the environment.
3.3.12 removal, v—the cleanup or removal of released hazardous substances from the environment; such actions as may be
necessary to take in the event of the threat of release of hazardous substances into the environment; such actions as may be
necessary to monitor, assess, and evaluate the release or the threat of release of hazardous substances; the disposal of removed
material; or the taking of such other actions as may be necessary to prevent, minimize, or mitigate damage to the public health
or welfare or to the environment, which may otherwise result from a release or threat of release.
3.3.12.1 Discussion—
The term includes, in addition, without being limited to, security fencing or other measures to limit access, provision of alternative
water supplies, temporary evacuation and housing of threatened individuals not otherwise provided for, action taken under section
104(b) of CERCLA, post-removal site control, where appropriate, and any emergency assistance which may be provided under the
Disaster Relief Act of 1974.
3.3.13 site inspection (SI), n—a systematic examination to determine whether there is a release or potential release and the nature
of the associated threats.
3.3.13.1 Discussion—
The purpose of the site inspection is to augment the data collected in the preliminary assessment and to generate, if necessary,
sampling and other field data to determine if further action or investigation is appropriate.
3.3.14 standard industrial classification, n—the Standard Industrial Classification is a system for classifying industries by a
four-digit code; established in the United States in 1937, it is used by government agencies to classify industry areas.
3.3.15 storage, v—the containment of hazardous substances, petroleum products or their derivatives, either on a temporary basis
or for a period of years, in such a manner as not to constitute disposal of such hazardous substances, petroleum products, or their
derivatives.
3.3.15.1 Discussion—
Storage of RCRA-regulated waste for a period that exceeds 90-days may require a permit issued by the EPA or a state with
delegated authority to enforce RCRA regulations.
3.3.16 user, n—the party seeking to use this guide to screen and characterize the property for the purpose of confirming past or
present uses of PFAS at the property and to confirm releases of PFAS to the environment.
3.3.17 visual and/or physical inspection, v—actions taken during a preliminary investigation to include observations made by
vision while walking through or otherwise traversing a property and structures located on it and observations made by the sense
of smell, particularly observations of sweet, aromatic, noxious or foul odors.
3.4 Acronyms Abbreviations, and Initialisms:
3.4.1 AFFF—aqueous film-forming foam
3.4.2 ATSDR—Agency for Toxic Substances and Disease Registry
3.4.3 ARARs—applicable or relevant and appropriate requirements
3.4.4 CERCLA—Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (42 USC 9620
et seq.)
3.4.5 CFR—Code of Federal Regulations
3.4.6 CSM—conceptual site model
3.4.7 DoD—Department of Defense
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3.4.8 EPA—United States Environmental Protection Agency
3.4.9 EPCRA—Emergency Planning and Community Right to Know Act, 42 USC
3.4.10 ERNS—emergency response notification system
3.4.11 ESA—environmental site assessment
3.4.12 GOCO—government-owned/contractor operated
3.4.13 LUST—leaking underground storage tank
3.4.14 NACE—European Classification of Economic Activities
3.4.15 NAICS—North American Industrial Classification System
3.4.16 NCP—National Contingency Plan (40 CFR Part 300)
3.4.17 NPDES—National Pollutant Discharge Elimination System
3.4.18 OB/OD—open burning/open detonation
3.4.19 PA—preliminary assessment
3.4.20 PFAS—perfluoroalkyl and polyfluoroalkyl substances
3.4.21 POTW—publicaly-owned treatment works
3.4.22 RCRA—Resource Conservation and Recovery Act, as amended, 42 USC 6901 et seq.
3.4.23 SARA—Superfund Amendments and Reauthorization Act of 1986
3.4.24 SDS—Safety Data Sheet
3.4.25 SEMS—Superfund Enterprise Management System
3.4.26 SI—site inspection
3.4.27 SIC—Standard Industrial Classification
3.4.28 TPD—technical policy decision
3.4.29 TRI—toxic release inventory
3.4.30 TSDF—treatment, storage, and disposal facility
3.4.31 UFP-QAPP—Uniform Federal Policy for Quality Assurance Project Plans
3.4.32 USC—United States Code
3.4.33 USGS—United States Geological Survey
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3.4.34 UST—underground storage tank
3.4.35 WWTP—wastewater treatment tank
4. Significance and Use
4.1 PFAS are widely used in commercial and industrial applications worldwide (see Fig. 1). PFAS are of concern due to their
documented persistence and their studied impacts on human health and the environmental. While there is no comprehensive source
of information on the many individual PFAS substances and their functions in different applications, a range of resources are
available to the practitioner. This guide provides information to assist the practitioner in navigating these challenges during the
initial screening and site characterization process.
4.2 The user should note that PFAS regulatory management framework at the federal and state level are evolving quickly.
Therefore, consultation with legal and technical representatives with knowledge of federal, state, and local PFAS regulations is
advised prior to use of this guide. Environmental audit policies or privileges may be applicable to some of the steps described in
this guide (see EPA, 2000).
FIG. 1 Activity/Industry that may be Sources of PFAS Use and Release
Source: AEI Consultants
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4.3 Multi-step Risk Management Framework:
4.3.1 The actions described in this guide are intended to provide a multi-step risk management framework to confirm, with
reasonable certainty, that PFAS may have been used at a federally-owned, publicly-owned, or privately-owned property. This
standard provides guidance on how to focus limited resources on using a multi-step process, illustrated in Fig. 2, to identify
property potentially impacted by on-site or off-site uses and releases of PFAS. Section 4.5 describes the use and occurrence of
PFAS. Section 4.6 describes activities at government and federal installations where PFAS use is expected. Section 4.7 broadly
outlines the industry sectors where the use of PFAS has been documented (Glüge, 2020 (2), Gaines, 2022 (3)).
4.4 PFAs History and Use:
4.4.1 In the 1940s, industrial processes to commercially produce PFAS were first developed. Since then, PFAS have been used to
make many industrial and consumer products worldwide. Since the 1950s, PFAS have been widely used in surface treatment
applications for paper, fabric, cookware and carpeting which allows these products and materials to repel oil, water, and stains.
In the 1960s, the United States Navy used PFAS to develop Aqueous Film Forming Foam products for firefighting applications
and the technology was patented by the U.S. Navy. Since the 1960s, the U.S. Food and Drug Administration (FDA) has authorized
several broad classes of PFAS for use in food contact substances due to their non-stick and grease, oil, and water-resistant
properties. Over the past 50 years, PFAS use has expanded in food and consumer products manufacturing and packaging and
industrial operations and applications worldwide. Restrictions or prohibitions on the use of PFAS in food and consumer products
have been enacted at the State and local level.
4.4.2 Release of PFAS during manufacture into the atmosphere may have occurred, and may be continuing to occur, followed by
subsequent redeposition of PFAS materials on land where PFAS can enter surface water and groundwater. Other potential sources
of PFAS emissions are dry cleaning and commercial laundry operations where clothing coated with PFAS-containing materials is
cleaned or laundered. Emissions from these sources may include particulate matter such as lint. Additionally, PFAS may be or have
been discharged without treatment to wastewater treatment plants or landfills, and eventually be released into the environment by
treatment systems that are not designed to mitigate PFAS. Industrial discharges of PFAS were unregulated for many years; however,
change is underway in the U.S. at both the state and federal level as well as internationally.
4.4.3 Broadly, consumer and industrial uses of PFAS-containing products and waste may releasePFAS into landfills and landfill
leachate, and into municipal wastewater, where it may accumulate undetected in biosolids which may be land applied. PFAS may
be subsequently used in soil amendments used to grow animal feed and food crops and produce for human consumption. The user
should be aware that federal, tribal, state, and municipal regulations affecting the management of PFAS, including air emissions,
wastewater discharges, biosolids, groundwater, surface water, and impacted soil are rapidly evolving and may include additional
reporting requirements. (4)
4.5 PFAs Use and Occurence:
4.5.1 PFAS containing chemicals have been used in a broad spectrum of federal and commercial activities, as illustrated in Fig.
1. The use of PFAS as a component of AFFF for firefighting at military installations, refineries, petrochemical manufacturing
facilities, tank farms, and airports is well known. PFAS are used as coatings for fabric and paper products to repel water and grease
(see ITRC’s PFAS Technical Guide). PFAS have also been components of vapor control mists for electroplating operations. Other
industrial uses of PFAS are described in this section as well.
4.6 Government and Military Installations Use of PFAs:
4.6.1 PFAS have been used in a variety of applications at government/military facilities, including as a component in AFFF, which
was routinely used at fire-fighting training areas and equipment test areas and is still used at crash sites and some fire suppression
systems in hangars. In addition, PFAS has been a component of mist-suppression compounds associated with electroplating
operations at federal facilities and government-owned, contractor-operated (GOCO) research and development plants. The
wastewater treatment plants (WWTP) at federal installations may releasePFAS as emissions and may discharge PFAS into receiving
waters as effluent. The biosolids produced by the WWTP may contain PFAS if PFAS were present in the influent.
4.6.2 Current and historical AFFFstorage and transfer areas at federally-owned facilities are of potential concern for release to
the environment. Historical reports of uncontrolled spills and the repeated use of AFFF during fire training and firefighting have
been correlated with higher concentrations of PFAS in surface water and groundwater. Discharges of liquids from fire-fighting
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FIG. 2 Initial Site Screening and Characterization Flow Diagram
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practices into stormwater and sewer systems and holding ponds are potential source areas. In addition, treated effluents from
remediation of other hazardous substances at the installation should be considered potential source areas.
4.6.2.1 Accordingly, key elements for identifying significant PFAS sources at federally-owned facilities are the storage and use
of AFFF.PFAS from AFFF used in firefighting and fire suppression systems are considered to have the greatest potential for release
of PFAS to the environment in terms of mass concentration at government/military installations.
4.6.2.2 Other potential sources of PFAS to the environment include historical on-site land disposal areas/landfills containing
operations wastes (for example, from electroplating), wastewater treatment sludges and effluents, or PFAS materials themselves.
Landfill leachate could carry PFAS to groundwater.
4.6.3 AFFF used in Fire-Fighting Exercises and Fire Suppression are water-based (60-90%) and frequently contain hydrocarbon-
based surfactants, such as sodium alkyl sulfate, and fluorosurfactants, such as fluorotelomers, PFOA, and/or PFOS. AFFF
containing PFAS were developed in the early to mid-1960s for use on Class B fires and were placed into routine use at government
installations by the early1970s and are still in use today.
4.6.3.1 Companies including 3M, DuPont, Ansul, and Chemguard were the primary fire-fighting foam producers that used
fluoro-chemical surfactants in the production of AFFF. Typically, AFFF concentrate was proportionally mixed into water lines
using in-line eductors or other proportioning devices to create the necessary foam solution ranging from 3 % to 6 % of the
concentrate. As noted, AFFF was primarily used with Class B fuel fires because the chemical properties of PFAS in AFFF created
a thick foam blanket. Class A fire-fighting foams were used to extinguish wood and grass fires and do not contain PFAS.
4.6.4 Open Burning / Open Detonation of Munitions—Open burning and open detonation of munitions are non-routine activities
at some military installations and federal facilities. The types of munitions that may contain PFAS are primarily limited to
pyrotechnics (flares). The open- burning, open-detonation of munitions is subject to Subpart X of the RCRA Permitting Process
(see 40 CFR 264, Subpart X).
NOTE 1—If the open detonation activities are conducted are part of the installation’s training program, they may not be subject to permitting under RCRA
Subpart X. Temperatures in munitions deactivation furnaces and rotary kilns reach up to 1500°F, which may not be adequate to destroy PFAS (EPA, 2005).
Open burning may not achieve temperatures high enough to destroy PFAS. The incomplete combustion of munitions as well as thermal deactivation
releasesPFAS into the air. Emissions associated with OB/OD of munitions travel downwind and should be considered in the fate and transport model.
OB/OD may leave residual PFAS and metals in soil.
4.6.5 Electroplating, specifically hard chromium plating, is an industrial activity where PFAS-containing mist suppressants may
have been used. PFAS were sometimes used during the chromium electroplating process as a surfactant in chromic acid baths.
Federal facilities where electroplating may have been conducted include Department of Defense installations where aircraft, heavy
equipment, and ships were overhauled and maintained. Government-owned, contractor-operated research and development plants
are also sites where electroplating operations have historically been conducted.
4.6.6 Landfill Operations, Waste Disposal Areas, and Wastewat
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