The U.S. Environmental Protection Agency (EPA) has announced proposed revisions to the national primary drinking water regulation for PFAS (per- and polyfluoroalkyl substances), raising concerns and prompting energy for utilities to take action.
Although PFOA and PFOS maximum contaminant levels (MCLs) remain at 4 parts per trillion (ppt) under the April 2024 rule, new proposals may rescind MCLs for GenX, PFNA, PFHxS, and the associated hazard index. The timeline for treatment compliance may be extended from 2029 to 2031, but monitoring and reporting requirements remain unchanged.
🗓️ Compliance Timeline: Monitoring and Public Notices Still Required
Utilities must continue required actions:
- Initial PFAS source monitoring by 2027
- Quarterly testing and reporting, with results included in Consumer Confidence Reports (CCRs)
- Public notification protocols for sampling or exceedance
Systems with MCL exceedances should assess treatment options—potentially by 2028—to meet the running annual average (RAA) requirement.
🧪 Why RAA Matters: Forward-Looking Compliance Planning
Compliance with PFAS regulations is determined using a four-quarter RAA, similar to how disinfection byproducts are regulated. Utilities with PFAS levels slightly above the MCL may reduce the need for extended treatment by starting it early. For systems with PFAS levels exceeding 10 ppt, pilot testing and possible early intervention may be necessary to remain compliant.
⚙️ Best Practices: Strategies for PFAS Preparedness
Jacobs recommends a multi-pronged strategy:
- Compile and analyze existing PFAS monitoring data—especially from UCMR 5—to prioritize high-risk water sources.
- Pilot treatment technologies such as granular activated carbon (GAC), ion exchange, and selective adsorbents.
- Use pilot data to model RAA compliance timelines and treatment media performance and cost.
- Plan capital and operational budgets accordingly—considering modular systems for smaller utilities and facility upgrades for larger ones.
- Monitor evolving state PFAS regulations, as state-level mandates may surpass federal requirements.
✅ Final Thoughts
Despite the proposed regulatory changes, the April 2024 PFAS rule remains enforceable until replaced. Water utilities near or above the 4 ppt threshold are encouraged to plan now. By prioritizing early treatment planning, piloting, modeling, and monitoring, systems can navigate the regulatory landscape with cost-effective strategies that protect public health and operational resilience.
