EPA Announces First-Ever Limits on PFAS in Drinking Water
Let's Break it Down
The U.S. Environmental Protection Agency announced the Final National Primary Drinking Water Regulation for six PFAS (Final PFAS Rule). This comes nearly 4 months later than expected. The delay was met with uncertainty and a flood of rumors — lower MCLs, higher MCLs, new PFAS added, select PFAS removed. None of these threads led to where we landed. The final regulation is largely unchanged from what was originally proposed — six MCLs, including five for individual compounds (PFOA, PFOS, PFNA, GenX, and PFHxS) and a Hazard Index MCL for PFNA, GenX, PFHxS, and PFBS to be regulated as a group. PFOA and PFOS have MCLGs of zero. The bottom line is that water utilities around the country must begin their compliance strategies to meet all regulatory requirements.
That isn’t to say there were no changes to the Proposed PFAS Rule. Indeed, one could argue that these modest modifications are a silver lining to an otherwise burdensome regulation. The requirements for reduced monitoring and the calculation to establish the Hazard Index were both (ever so slightly) relaxed. More importantly, utilities now have three years, until 2027, before the annual notifications and information in the CCR begins and five years, until 2029, before MCL violations require Tier 2 (30-day) notification. The EPA also acknowledged an opportunity for an extension on MCL compliance for those that qualify. The good news is that we have more clarity on the rule and more time to comply. The bad news: the clock is now ticking, and the overall lift has not changed.
A big question — how much will this cost? The American Water Works Association estimates nearly $4 billion a year. The EPA estimates rule compliance will cost approximately $1.5 billion a year. Utilities have to understand the true costs of testing, monitoring, and treatment with market volatility and supply/chain fluctuations. Now is the time to get your estimates.
Practical Steps Towards PFAS Compliance
Water utilities are just receivers of PFAS, though they are now placed on the front line for minimizing our exposure. Federal funding is available, though limited. The public is aware and concerned. How should utilities plan and respond? How should they communicate with their customers?
Consider developing a roadmap. HDR's PFAS Roadmap Approach
I’m a big proponent of this framework. It outlines a practical plan for effective PFAS compliance and strategic communication.
Ultimately, I still believe our best strategies for this complex challenge are those we develop together. These contaminants are persistent and ubiquitous, and pose public health concerns at part per trillion levels. The long-term life cycle costs for compliance may be significantly reduced if we incorporate holistic approaches to minimize PFAS in the environment. It's profoundly logical — we decrease PFAS coming into our sources of supply and, over time, we may be able to decrease the effort we need to remove it. This embodies a One Water mindset and has the potential to connect all of us in the search for sustainable PFAS solutions.
Terminology
- CCR - consumer confidence report
- GenX - trade name for chemical hexafluoropropylene oxide dimer acid (HFPO-DA) and its ammonium salt
- MCL - maximum contaminant level
- MCLG - maximum contaminant level goal
- PFAS- perfluoroalkyl and polyfluoroalkyl substances
- PFBS - perfluorobutane sulfonate
- PFHxS - perfluorohexane sulfonate
- PFNA - perfluorononanoic acid
- PFOA - perfluorooctanoic acid
- PFOS - perfluorooctane sulfonic acid
