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Final PFAS National Primary Drinking Water Regulation: What Utilities Need to Know
Overview of the EPA Final PFAS Regulation
On April 8, 2024, The U.S. Environmental Protection Agency (EPA)finalized the PFAS National Primary Drinking Water Regulation (NPDWR), published in the Federal Register on April 26, 2024 (89 FR 32532). The rule becomes effective on June 25, 2024, with compliance requirements phased in over the five years.
Since the release, several water organizations have raised concerns. The new EPA Administrator, Lee Zeldin, has indicated the regulation may be revised. This article outlines key compliance requirements for Public Water Systems (PWSs) and highlights areas that may change.
Maximum Contaminant Level Goals (MCLGs) and Maximum Contaminant Levels (MCLs) for PFAS
The rule establishes enforceable Maximum Contaminant Levels (MCLS) and health-based Maximum Contaminant Level Goals (MCLGs) for several per- and polyfluoroalkyl substances (PFAS). To learn more about PFAS learn more here.
Table of PFAS MCLGs and MCLs
The regulation established enforceable Maximum Contaminant Levels (MCLs) and health-based Maximum Contaminant Level Goals (MCLGs) for several PFAS compounds:
Analytical Methods for PFAS Detection
The Final PFAS National Primary Drinking Water Regulation (NPDWR) approved analytical methods for PFAS detection. Compliance with these methods is required by June 25, 2024.
- EPA Method 533
- EPA method 537.1
- (both using Solid Phase Extraction Liquid Chromatography Mass Spectrometry – SPE LC MS/MS).
Best Available Technologies (BATs) for PFAS Treatment
EPA identified the following Best Available Technologies (BATs) for PFAS treatment.
- Granular Activated Carbon (GAC)
- Anion Exchange (IX)
- Reverse Osmosis (RO)
- Nanofiltration (NF)
Utilities can also meet compliance by removing contaminated sources or adding new uncontaminated sources. The rule gives public water systems flexibility to determine the best approach for their utility. Generally, treatment facility plans must be approved by the primacy agency (e.g. state agency responsible for NPDWR enforcement, EPA on most Indian Lands).
Public water systems may also achieve compliance with the Maximum Contaminant Levels (MCLs) by removing the contaminated sources of water or by adding new uncontaminated sources.
Monitoring and Reporting Requirements
Initial Monitoring
- Surface water, groundwater, and groundwater under the direct influence (GWUDI) of surface water Community Water Systems (CWSs) and Non-Transient, Non-Community WaterSystems (NTNCWS) serving >10,000 people: Four quarterly samples by April 26, 2027 (e.g. entry point to the distribution system – EPTDS)
- Groundwater CWS and NTNCWS serving ≤ 10,000 people: Two biannual samples by April 26, 2027
- Use of UCMR 5 Data: Allowed if samples were collected with approved methods
All results must be reported by April 26, 2027. The initial monitoring results will be used to determine the frequency of future compliance monitoring.
All results must be reported by April 26, 2027. The initial monitoring results will be used to determine the frequency of future compliance monitoring.
Compliance Monitoring and Frequency Trigger Levels
- Compliance monitoring must be commenced no later than April 26, 2027.
- Default Frequency: Quarterly, unless the results of initial monitoring are less than the following trigger levels for all contaminants:
*Note: The Hazard Index and associated contaminants (HFPO-DA, PFBS, PFHxS, PFNA) may be eliminated in a future revision.
- If results of initial monitoring for all PFAS contaminants are less than trigger levels compliance monitoring frequency can begin at triennial, however once compliance monitoring begins, a water system cannot transition directly from a quarterly to triennial frequency.
- Compliance monitoring frequency may be reduced to annual if results are above trigger levels, but reliably and consistently below MCLs as approved by the primacy agency.
- The PWS would have to return to quarterly monitoring if any future results are equal to or greater than the trigger levels or exceed MCLs.
- Compliance will be based on a running annual average of analytical results.
PFAS Hazard Index (HI) and Compliance Calculations
What is the Hazard Index (HI) Calculation?
- The Hazard Index (HI) is a calculated value that is determined by dividing the analytical result for each PFAS with their associated Health Based Water Concentration (HBWC) to arrive at a Hazard Quotient (HQ).
How is the Hazard Index (HI) Calculated?
- The Hazard Index is calculated by dividing each PFAS result by its Health-Based Water Concentration (HBWC) and summing the values:
(Note: The HI and associated contaminants HFPO-DA, PFBS, PFHxS, PFNA, may be eliminated from a proposed revised rule.)
Calculation Key:
- Where HFPO-DAwater = monitored concentration of HFPO-DA in ng/L
- PFBSwater = monitored concentration of PFBS in ng/L
- PFNAwater= monitored concentration of PFNA in ng/L
- PFHxSwater = monitored concentration of PFHxS in ng/L
- Denominators = HBWCs
The presence of PFBS can only trigger an MCL violation if it is present as part of a mixture with at least one of the other three PFAS (i.e. PFHxS, PFNA and HFPO-DA). More information on the Hazard Index and example calculations can be found here.
Compliance Deadlines and Public Notice Requirements
Public Water systems must notify customers of monitoring results and any violations. EPA has published compliance resources, available at Per- and Polyfluoroalkyl Substances (PFAS) | US EPA.
Key Deadlines:
- June 25, 2024: Analytical requirements effective
- April 26th, 2027: Initial monitoring complete and results reported
- April 26th, 2027, onward: Compliance monitoring begins.
Public Notice Requirements
How NJBSoft Can Help with PFAS Compliance
Automating Monitoring
Managing new PFAS monitoring and reporting requirements can be complex. SAMS Water by NJBSoft streamlines compliance by:
- Scheduling and tracking sampling events
- Ensuring compliance with EPA-approved methods
- Automating reporting and data submission to primacy agencies
- Providing centralized access to monitoring data for audits and inspections.
Staying Flexible for Future PFAS Rule Revisions
With potential revisions to the PFAS rule, SAMS Water gives utilities flexibility to adjust monitoring schedules and maintain compliance with both current and future requirements
Stay Informed On PFAS Regulations
PFAS regulations are evolving. Utilities should consult their state primacy agencies and monitor EPA updates. NJBSoft will continue to provide insights and tools to help utilities manage compliance effectively.
Learn more about how SAMS Water Compliance software can help your utility stay ahead of PFAS here.
FAQs
The Final PFAS NPDWR is an EPA rule issued in April 2024 that sets enforceable limits for several PFAS chemicals in public drinking water systems. Compliance is phased in over five years, beginning June 25, 2024.
The rule establishes Maximum Contaminant Levels (MCLs) for PFOA, PFOS, PFHxS, PFNA, and HFPO-DA, along with a Hazard Index (HI) for mixtures of multiple PFAS.
Water systems must complete initial monitoring by April 26, 2027. Large systems must take four quarterly samples, while smaller systems take two biannual samples. Compliance monitoring begins in 2027 and continues quarterly unless reduced by the primacy agency.
EPA identifies Granular Activated Carbon (GAC), Anion Exchange (IX), Reverse Osmosis (RO), and Nanofiltration (NF) as Best Available Technologies (BATs). Systems may also switch to uncontaminated water sources.
The Hazard Index evaluates the combined risk of multiple PFAS. It is calculated by dividing each PFAS concentration by its Health-Based Water Concentration (HBWC) and summing the results. A value above 1 triggers a compliance violation.
SAMS Water by NJBSoft automates sampling schedules, tracks monitoring deadlines, and simplifies reporting to primacy agencies. It helps utilities adapt quickly if EPA revises PFAS regulations in the future.
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About The Author
At NJBSoft, we’re proud to collaborate with experts like Robert Hollander, P.E., whose extensive experience in water quality and regulatory compliance allows us to design SAMS in order to meet industry needs. Bob’s leadership and deep industry knowledge supports utilities in staying organized, compliant, and focused on protecting public health every day.
Robert Hollander
- 45 years of experience in water quality, regulatory compliance, and utility management
- President of Hollander Consulting Services
- Held senior roles at the City of Peoria, City of Phoenix, and the Arizona Department of Environmental Quality
- Served as President of the AZ Water Association and the Western Coalition of Arid States
- Licensed Professional Engineer in Arizona with multiple Grade 3 operator certifications
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