From: Twohig, Eamon Sent: Monday, July 1, 2019 8:43 AM To: Regulations, BWSC (DEP) Cc: Information, BWSC (DEP) Subject: Comment on proposed MASS DEP Waste Site Cleanup Regulations I have reviewed the proposed PFAS standards for soils under the waste site cleanup regulations: https://www.mass.gov/lists/2019-proposed-mcp-revisions and understand that the combined 6 PFAS limit in soil (S-1, 2, and 3) in GW-1 areas is proposed at 0.2ppb. I wanted to be sure that Mass DEP has reviewed the recent UVM study/report on background PFAS levels in shallow Vermont soils: https://anrweb.vt.gov/PubDocs/DEC/PFOA/Soil-Background/PFAS-Background-Vermont-Shallow- Soils-03-24-19.pdf. The study found BACKGROUND for PFAS (sum of 17 analytes) ranged from 0.5 to 35 ppb. Nearly all of the samples from shallow soils showed PFOS > 0.2ppb. By this logic, I’d speculate that normal, non-industrially impacted soils in MASS will not meet the proposed soil standard of 0.2 ppb. Thank you, Department of Environmental Conservation Waste Management & Prevention Division Residuals Management & Emerging Contaminants Program Eamon Twohig 1 National Life Drive, Davis 1 Montpelier, VT 05620-3704 802-490-6189 Eamon.Twohig@vermont.gov ”Note: Written communications to and from state officials regarding state business are considered public records and will be available to the public for review.”