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EPA Issues Guidelines on Use of Previously Collected PFAS Data
The U.S. Environmental Protection Agency (EPA) has issued new guidelines to help water systems meet the requirements of the final PFAS National Primary Drinking Water Regulation (NPDWR). These guidelines explain how water systems can use past PFAS test results to meet initial monitoring requirements and determine how often they need to test in the future.
The final NPDWR sets legal limits for five PFAS chemicals—PFOA, PFOS, PFNA, GenX (HFPO-DA), and PFHxS—as well as a combined limit for mixtures of PFHxS, PFNA, HFPO-DA, and PFBS. Community and non-transient non-community water systems must complete initial monitoring by April 26, 2027.
Monitoring Requirements:
- Groundwater systems serving more than 10,000 customers and all surface water systems must collect four quarterly samples over a 12-month period
- Groundwater systems serving 10,000 or fewer customers must collect two semi-annual samples over 12-month period
- Water systems may use past PFAS data (from programs like UCMR 5) if it meets EPA standards and was collected on or after January 1, 2019
- If past data is incomplete, systems can take extra samples to meet requirements
Ongoing Testing:
- If all PFAS levels in initial tests are below half of the Maximum Contaminant Level, systems may qualify for less frequent testing
- All tests must be performed by EPA-certified labs using approved methods
The EPA is working with labs to reprocess data for small water systems. Larger systems must contact their labs for updated results. These efforts help ensure that water systems can monitor PFAS efficiently while keeping drinking water safe.
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