It’s the last month of 2024, and what a year it’s been! It has been our pleasure to bring you the latest PFAS headlines and share our insights into how these news stories may impact your organization, community, or business. Here are a few more that may have slipped under the radar while folks have been busy with the start of the winter holidays.
Latest Results from October Release of UCMR 5 Data
The U.S. EPA released another round of UCMR 5 data in October. Here are a few highlights from the full data summary:
Results for recently regulated contaminants were consistent with July’s data, with only PFOS, PFOA, and HFPD-DA (GenX) inching up, but by less than 1.0%. The percentage of regulated PFAS above the hazard index limit declined slightly, from 1.0% in July to 0.9% in the most recent report. The percentage of PWSs reporting one or more averages greater than the MCL set by the NPDWR was up slightly from 11% in July to 12% in Oct.
Source: The Fifth Unregulated Contaminant Monitoring Rule (UCMR 5) Data Summary: October 2024
Of the 23 still-unregulated contaminants included in UCMR 5 (22 PFAS plus lithium), lithium remains the only contaminant found in concentrations above the reference limit. The percentage of Public Water Systems (PWSs) that measured higher than the reference limit stayed fairly level at 25.5%.
Source: The Fifth Unregulated Contaminant Monitoring Rule (UCMR 5) Data Summary: October 2024
Using UCMR 5 Sampling Data for NPDWR Reporting
We are getting a lot of questions from clients about how to use UCMR 5 data to fulfill National Primary Drinking Water Regulations (NPDWR) sampling requirements. We are happy to answer individual questions. Contact us here. Our team will also be conducting a primary drinking water webinar this month, and they plan to address this topic. You can register for the webinar here.
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Private Well Testing for PFAS
Our consulting partners and private property owners frequently ask us about testing private wells for PFAS. The U.S. EPA mandates for drinking water testing do not apply to private wells. Some state mandates, such as New Jersey’s Private Well Testing Act, are beginning to apply to private well testing.
Even if testing is not yet mandated, private wells can also be susceptible to PFAS contamination. We suggest private well owners consult the U.S. EPA’s PFAS Analytical Tools to determine if PFAS levels in local systems are above the primary drinking water MCLs. If they are, private well testing is likely warranted.
17 PFAS Added to EPA’s Significant New Use Rule
On November 29, the U.S. EPA published a supplemental notice of proposed rulemaking, adding seventeen PFAS to the EPA’s Significant New Use Rule (SNUR). This rule requires any entity intending to manufacture or import these compounds for an activity that qualifies as a “new use” under the rule to notify the EPA 90 days prior to initiating the activity. These entities must also wait until the EPA has finalized its review and taken any actions it deems appropriate. The seventeen compounds belong to three categories: fluoroalkylacrylate copolymer (generic), fluorochemical urethane (generic), and fluoroalkyl acrylate (generic).
Current Status of EPA’s POTW ICR
Earlier in the year, we conducted a webinar on the EPA’s proposed Information Collection Rule (ICR) for Publicly Owned Treatment Works. The public comment period for the proposal closed on November 12, 2024. This is one of the outstanding action items we fully expect the agency to finalize before the end of the year. If you are part of a POTW and were not able to make it to our recent webinar on the ICR proposal, I encourage you to watch it on-demand.
Watch: US EPA Information Collection Rule (ICR) Proposal for PFAS and NPDES
Reminder: 2024 TRI Reporting Expanded
As reported by Mondaq and others, the number of PFAS on the Toxic Release Inventory (TRI) expanded by 196 compounds for reporting-year 2024. The EPA estimated that the increased reporting requirements would require almost 2,000 more companies to report PFAS releases. Reports for 2024 are not due until July 1. We are also monitoring the EPA’s proposal to add roughly 100 more PFAS compounds for reporting-year 2025.
Upcoming Webinars
The Pace® PFAS team is conducting two webinars this month on critical topics for our clients:
Navigating the Complexities of Testing for PFAS in Plant and Animal Tissue
Our PFAS team is getting more questions than ever about analyzing PFAS in biota. Jim Occhialini, Pace® Specialty Services Program Manager, will be addressing this topic on December 11 at 11:30 ET.
PFAS Maximum Contaminant Levels (MCLs) Insights: What, When, & How
In our recent CERCLA webinar, we had almost as many questions about drinking water regulations as about the CERCLA program. Clearly, there are still a lot of questions around the PFAS limits and testing requirements, so Paul Jackson, Pace® Program Manager for Environmental Compliance, will be revisiting the topic on December 18 at 11:30 ET.
All the Best for the New Year!
I would like to be among the first to wish all of our clients and blog readers happy holidays and the warmest wishes for the coming year. 2025 looks to be a busy year for both Pace® and our clients. New regulations and programs will certainly be implemented at the state and federal levels. We will be here to answer your questions and help you plan to meet any new obligations. Behind the scenes, we are also working with the U.S. EPA and other institutions to advance the science of PFAS testing across multiple matrices, and we cannot wait to share the latest developments.
