PFAS Sampling: New Regulations and Implications for Operators

Over the last few years, PFAS have quickly become a buzzword in the water and wastewater industry. PFAS, or Polyfluoroalkyl Substances, are man-made “forever” chemicals used in various products, including nonstick cookware, waterproof clothing, and firefighting foam. These chemicals are extremely persistent and do not naturally break down, leading to widespread contamination.

PFAS are linked to numerous health effects, including increased high blood pressure in pregnant individuals, developmental delays in children, an increased risk of cancer, reduced immune system function, hormonal interference, increased cholesterol levels, and liver damage. PFAS have been widely detected in water systems, wastewater systems, and wastewater biosolids across the country, prompting a push for the EPA to enforce stricter PFAS regulations under the Safe Drinking Water Act.

PFAs Regulation

On April 10, 2024, the EPA implemented new PFAS regulation by adding PFAS to the National Primary Drinking Water Regulation (NPDWR). This regulation established a maximum contaminant level (MCL) for six specific PFAS, including PFOA, PFOS, PFNA, PFHxS, PFBS, and GenX. This list may expand as more PFAS are detected in water supplies. The MCL is an enforceable limit, and the EPA also provides a Maximum Contaminant Level Goal (MCLG).

The chart below illustrates the PFAS chemical MCL and MCLG:

EPA Strategic Roadmap

The EPA acknowledges that the PFAS issue extends beyond drinking water facilities and has developed a strategic roadmap to limit PFAS contamination at the source. This includes finalizing rules for new and existing PFAS use reporting, certifying EPA Method 1633 for PFAS analysis, developing rules to limit manufacturers’ discharges of PFAS, and issuing guidance to states on using NPDES permits to monitor and restrict PFAS discharges. This comprehensive approach supports the enforcement of PFAS regulation at multiple levels, from production to disposal.

What Does This Mean for Operators?

The new regulations will not require PFAS sampling until 2026. Systems not in compliance with the MCL will need to implement a solution to reduce PFAS levels by 2029. If a system still exceeds the MCL by 2029, action must be taken to bring PFAS levels below the MCL. This may include adding treatment options or evaluating alternative water sources.

Initial monitoring will be required to determine if ongoing compliance monitoring is required.

• 4 quarterly samples for all surface water systems and for groundwater systems serving over 10,000.
• 2 semi-annual samples for groundwater systems serving below 10,000.

Ongoing monitoring is based on the initial PFAS sampling results. Systems that test lower than the trigger levels will only be required to sample once every three years. Systems that test greater than the trigger levels are required to complete quarterly monitoring until they have four consecutive samples below the trigger level. Then those systems can move to annual sampling and eventually to sampling every three years. If there is a sample above the trigger level, the system returns to quarterly sampling. All sampling results must be available to the public.

There are no waivers allowed for PFAS sampling. When sampling, the results are based on the average of samples, and any sample below the PQL (practical quantitation limit) is considered zero.

PFAS Sampling Do’s and Don’ts

For accurate PFAS sampling, and to avoid contamination of the samples, follow these guidelines:

Do

• Use an accredited lab 
• Follow instructions given by the lab and use lab-approved materials for sampling
• Wear gloves (nitrile)
• Wear clean, cotton clothes
• Use PFAS-free blank water for a certificate of analysis
• Ice samples within 15 minutes of collecting

Don’t

• Use Teflon tubing, bottles, or caps
• Use chemical ice packs (Blue ice)
• Wear cologne, perfume, moisturizers, hand cream, sunscreen, insect repellent or other hygiene products
• Use aluminum foil, prepackaged food, fast food wrappers or containers
• Use clothing or boots with Gore-Tex or other synthetic water-resistant and/or stain-resistant materials, Tyvek material, fabric softener
• Use waterproof/treated paper or field books, plastic clipboards, waterproof markers, post-it notes, or other adhesive paper products
• Wear new clothes
• Touch sampling tap with hands or sample bottle

What if PFAS is found in your water supply?

If PFAS is detected in your water supply, you should resample and confirm. Then notify the public and the regulatory agency. Next, try to identify the PFAS source. Do all the water sources contain PFAS? Is there only one well that is positive for PFAS? Systems should evaluate if other water sources could be used that don’t contain PFAS. If the water source cannot be changed, systems should start evaluating treatment options and costs.

Funding for Water Improvements

The Bipartisan Infrastructure Law (BIL) provides up to $9 billion to address PFAS and other emerging contaminants. Another $4 billion is earmarked for the Drinking Water State Revolving Fund, and $5 billion is reserved for emerging contaminants under the disadvantaged communities grant program. Additionally, $12 billion is available for general water improvements, including PFAS. Several other funding sources are available, including WIFIA and federal loans. The EPA also offers a free technical assistance program for disadvantaged communities.

Treatment for PFAS Removal

There are many treatment options available to remove PFAS. These include granular activated carbon (GAC), reverse osmosis (RO), ion exchange, and nanofiltration. All these options will likely be implemented after existing treatment and before disinfection.

• GAC uses activated carbon to filter and adsorb contaminants. Over time, the carbon media would need to be disposed of.
• Reverse osmosis uses membranes to filter contaminants using high pressure. There is a treated stream and a waste stream. Systems would need to safely treat the discharge from the waste RO stream.
• Ion exchange causes PFAS, which are negatively charged, to attach to the positively charged ions in the filter. Similar to the GAC, the media filters need to be removed or backwashed.
• Nanofiltration uses very small filters to filter out the PFAS. The filters require backwashing and treatment or discharge of the backwash wastewater.

Partner with HR Green for PFAS Compliance

Navigating the new PFAS regulations and achieving EPA compliance can be challenging for any water and wastewater facility. With new standards coming into effect, it’s essential for operators to stay informed and proactive. At HR Green, we offer comprehensive support to help you address these challenges effectively and efficiently.

From feasibility studies through construction phase services, our team of dedicated water engineering professionals is committed to delivering reliable, cost-effective, and innovative solutions tailored to your specific needs. We work closely with both public and private sector clients, understanding their unique challenges and developing the right solutions to meet those needs. Our focus on schedules and budgets means we prioritize your interests while adhering to established timeframes and financial constraints.

Our PFAS Engineering Services include:

• Planning + Feasibility
• Design
• Funding Assistance
• Wells + Well Fields
• Storage
• Liquid Treatment
• Solids Handling
• Construction Phase
• Regulatory and Permitting

If you’re looking to navigate the new PFAS sampling regulations and enhance your water and wastewater systems, we invite you to reach out to our team. Let’s discuss how our services can support your project goals and help you stay compliant with the latest standards. Contact us today to learn more about how we can assist you in achieving your water management objectives.

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