Pace® PFAS News and Views – October 2025

The last few weeks have been very busy for the PFAS team here at Pace®. Typically, I cover both federal and state PFAS action in our monthly newsletter. However, with the publication of the Spring Unified Agenda, there is so much activity at the federal level I decided to make that our sole focus in this month’s PFAS News & Views.  

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EPA Signals PFAS Actions Ahead 

While the Unified Agenda doesn’t always offer as many details on what the U.S. EPA has planned as we might like, the preliminary timeline it provides can help you be better prepared. In a recent post, Paul Jackson, Pace® Program Manager for Environmental Compliance, offered his assessment of the PFAS-related actions included in the Spring 2025 Unified Agenda. Read: 9 PFAS-Related Items on the OMB’s Unified Agenda.   

Here are some of the actions we should anticipate just in Q4 of 2025: 

September 2025 – Removal of PFAS – except PFOA and PFOS – from the National Primary Drinking Water Regulations (NPDWR). Notice of Proposed Rulemaking (NPRM) to be issued for public comment.  (As I write this, the NPRM has not been released, but it’s likely the shutdown has impacted the timeline.) 

October 2025 – NPDWR compliance deadline extension. NPRM to be issued for public comment. 

November 2025 – Changes to the Toxic Release Inventory (TRI) supplier notification rules. Final rule scheduled for publication. 

November 2025 – Addition of PFAS to National Pollutant Discharge Elimination Systems (NPDES) permitting. NPRM to be issued for public comment.   

December 2025 – Toxic Substance Control Act (TSCA) reporting exemptions and scope change. NPRM to be issued for public comment.  

PFAS in NPDES Permitting 

For Pace® clients, another noteworthy rule change will be the addition of PFAS to NPDES permitting. This has already been happening in several states, and the EPA has been actively publishing more materials to help NPDES permit writers include PFAS in NPDES permitting. It was good to see them include both EPA 1633 and ASTM D8421 in the online FAQ. They also talked a little more about sample cross contamination. For a deeper dive into these two topics, here are a couple of on-demand webinars you may find helpful.  

Watch: A Deep Dive Into EPA 8327/ASTM D8421 

Watch: Is PFAS Sample Cross-Contamination Caused by Sampling 

EPA Determines the PFAS Future Under CERCLA 

For months, there’s been ongoing speculation about the future of PFAS under CERCLA. On September 17, 2025, the agency put that issue to bed with a press release announcing the intention to keep the Hazardous Substances designation in place for PFOA and PFOS. They also plan to build a framework for future designations. This could be a welcome addition for many of our clients if it can provide more transparency to the process. 

I’ve been getting a few questions about the agency’s approach to Passive Receivers as outlined in the press release. Paul Jackson is currently drafting his thoughts on what this means for our clients. That post should be released within the next few days, but if you have questions in the meantime, feel free to reach out to us. 

NDAA Bill Proposals Reconsider PFAS Restrictions 

While it’s not directly connected to the EPA, the National Defense Authorization Act (NDAA) has implications for some of our clients. PFAS have been included in the NDAA since 2020, and the FY2026 versions passed by the House and Senate both contain PFAS-related clauses. Here’s a quick summary: 

House version:  

• Section 312 – Directs the Secretary of Defense to carry out an annual cost assumption analysis for the investigation and remediation of PFAS. Among other considerations, the annual analysis is required to consider advancements in technologies for treatment and disposal as well as the results from ongoing assessments of PFAS at key sites. 

• Section 313 – Extends the deadline for replacing Aqueous Film-Forming Foam (AFFF) with Fluorine-Free Foams (F3) for fighting fires on military installations. Oceangoing vessels and other instances where F3 may not be the best option continue to be exempted. 

• Section 314 – Requires the DOD to provide safe drinking water to households with private wells impacted by PFAS from military activities. 

• Section 322 – Directs the Secretary of Defense to designate a Coordinator for Engagement with Defense Communities Affected by PFAS within 12 months of passage of the FY2026 NDAA.   

Senate version: 

• Section 315 authorizes the Secretary of Defense to destroy or dispose of PFAS using any method that is cost-effective and permissible by any state or federal agencies that regulate the disposal or destruction of such compounds. This section also requires the DOD to update its PFAS destruction and disposal guidance. 

• Section 333 requires the Secretary to submit an annual report to the Committees on Armed Services of the Senate and the House on the funding and status of interim remedial actions taken by the DOD. 

The next step is for the House and Senate to start the reconciliation process in which both houses attempt to approve a consolidated bill that aligns to the President’s budget. 

EPA Updates Biosolids Use and Disposal Statistics 

Lastly, the EPA updated its Biosolids Use and Disposal Statistics page in late September. This site summarizes data submitted by more than 2000 large Publicly Owned Treatment Works (POTWS) that land apply, incinerate, or dispose of sewage sludge via surface disposal. For all the concern about PFAS in biosolids, nearly 60% of these POTWs still land-apply their biosolids. Of these, 53% said they did so for agricultural purposes and another 34.5% said they did so for distribution and marketing, which could also include sludge used for agricultural purposes as well as that sold or given away for home use. 

The team recently conducted a fascinating webinar on the challenges of quantifying PFAS in biosolids. As usual, Nick Nigro, Pace® PFAS Product Manager, went into details on the available test methods, providing helpful insights that can bolster your compliance and remediation efforts. 

Watch: Biosolids Analysis for PFAS: Challenges, Considerations, and Options 

EVENTS & CONFERENCES  

If you are in the area or attending one of these upcoming events, we would love to meet with you. Contact us to request a meeting.      

EFO Annual Meeting and Tradeshow, Tulsa, OK, October 13-15.  

AEHS 41st Annual International Conference on Soils, Sediments, Water, and Energy, Amherst, MA, October 20-23. During the Session 5 time slot, Nick Nigro will be co-presenting with Liz Denly, PFAS Initiative Leader & Chemistry Director, from TRC. Their topic will be the analysis of PFAS in consumer products. Nick will also be co-presenting a poster along with Rock Vitale, Senior Principal Chemist at CTEH, on the use of Total Organic Fluorine as a proxy method for PFAS analysis.  

Georgia Rural Water Association Fall Conference, Helen, GA, October 27-29. At 10:00 on the 28th, I will present the What, When and More Changes of the PFAS NPDWR MCLs.  

Illinois Rural Water Association Conference. Rockford, IL October 28-29, Paul Jackson from Pace® will present a session on PFAS MCLs, the “what, when, and how” at 3:00 on October 29th.   

WEASC Operators Conference, Myrtle Beach, NC, November 3-5. I will be presenting a session on November 4th at 11:25 discussion PFAS sampling and test methods for drinking water and wastewater operators. 

27th Annual Railroad Environmental Conference, Urbana, IL, November 11-12.  

We’re Here to Help 

As always, if you have questions or concerns about the sciences of PFAS testing, compliance, and remediation, don’t hesitate to reach out.