It could still be the PCV...in that you may have installed the Rev.-P PCV with an open rear breather tube. If its rear breather tube is open...you need Rev.-R PCV; 06F 129 101 R...as it has a check valve to seal and vacuum. If you have installed the correct PCV and have an open rear breather tube...then it may be the rocker cover itself is no longer sealing the EVAP and PCV passages inside.
But, it is possible there is a leak somewhere. You don't have VCDS so someone else will need to test for leaks by looking at STFT (MB 033) and LTFT (MB 032) data for you. But yes, it probably has a leak or more.
Or...you just give it a thorough inspection yourself. Or make up your own smoke tester and give that a try.
Another slim possibility would be the throttle-body unit is failing.
Having someone pull up its DTC's would be helpful...but it doesn't code for a leak unless fuel trims have exceeded 25% rich or lean.