Per- and Polyfluoroalkyl Substances (PFAS)

Per- and Polyfluoroalkyl Substances (PFAS)
State Drinking Water Program Challenges

ASDWA Comment Letters and Testimony: 

  • ASDWA letter of comment on EPA’s Draft Interim Recommendations for Addressing Groundwater Contaminated with PFOA and PFOS – June 10, 2019: ASDWA’s comments make note of ASDWA’s previous comments to EPA on multiple PFAS topics and provide new suggestions for EPA that are both directly related to the recommendations in the document and also in the broader context of cleanup program efforts and in related guidance.
  • Joint ASDWA Letter of Comment with ECOS, ACWA, and ASTSWMO on EPA’s PFAS Action Plan – April 4, 2019:. While the letter commends EPA for the development of the Action Plan and acknowledgement of state challenges, it also recommends that the Action Plan needs to:  consider setting limits for other PFAS (beyond PFOA and PFOS) in various media; focus on keeping PFAS out of the environment; provide timelines for actions; and address PFAS as a class.
  • ASDWA Letter to EPA on Clarifying Use of the DWSRF for PFAS and Unregulated Compounds – January 23, 2019: ASDWA submitted a letter recommending that EPA publish a memo clarifying that states can use the DWSRF to assess and address PFAS and other unregulated contaminants with adverse human health effects to allow water systems to get priority points on DWSRF loan applications to purchase and install additional treatment technology to remove these compounds.
  • ASDWA Letter of Comment on EPA’s Draft Toxicity Assessments for GenX and PFBS – January 22, 2019: ASDWA’s comments on EPA’s Draft Toxicity Assessments summarize state and water system challenges with EPA issuing HAs and toxicity assessments versus a Safe Drinking Water Act (SDWA) regulation with an established Maximum Contaminant Level (MCL).
  • ASDWA Letter of Comment to EPA on CCL5 and UCMR5 – December 4, 2018: ASDWA’s comments included recommending that PFAS (as a group) be included in the final Fifth Contaminant Candidate List (CCL5). The letter also included reference to ASDWA provided informal recommendations to EPA on the inclusion of more PFAS compounds in the final UCMR5.
  • ASDWA President’s Congressional Testimony on PFAS – September 6, 2018: ASDWA President, Lisa Daniels provided testimony at a PFAS hearing of the Subcommittee of the Environment of the House Energy and Commerce Committee asking Congress to direct federal agencies to develop unified risk messaging; list PFAS as a hazardous substance; provide additional funding to EPA and states; and expand the PFAS focus to encompass all programs and media; and more.
  • ASDWA Letter of Comment to EPA PFAS Docket – July 20, 2018: ASDWA submitted its letter of comment to the EPA PFAS National Leadership Summit and Engagement comment docket (EPA-HQ-OW-2018-0270) at The letter emphasizes the continuing challenges and continuing need to address all ASDWA’s recommendations from the January 12, 2018 letter, and the need to do more to ensure the protection of public health from PFAS compounds through the provision of safe drinking water. In addition, the letter expressed support for EPA’s current commitments and highlighted the need for EPA to take additional actions to: work with CDC ATSDR on health risks and messaging; develop a national plan that includes PFAS actions with a budget and timeline; address multiple PFAS compounds holistically through all EPA programs and media and at the source; include PFAS compounds again in UCMR5; and consider needs and implications for state and EPA funding that is being diverted from essential core drinking water activities to address PFAS contamination.
  • ASDWA PFAS Letter of Recommendations to EPA and CDC – January 12, 2018ASDWA sent a letter to EPA and CDC with detailed recommendations to assist states with the growing problem of PFAS in drinking water by forming a federal-state working committee and developing a unified message, promptly, to the public and state regulators on what to do about PFAS. The letter also provides specific recommendations for multiple categories of topics including:  direct engagement with states on any new PFAS advisories and guidelines; the need for more health effects research for additional PFAS compounds and considerations for analytical methods; as well as guidance for wastewater discharges, underground injection control, soil leaching standards, and air emissions.

ASDWA Resources:

  • NEW! Version 2: ASDWA PFAS Lab Testing Primer for States and Water Systems – February 14, 2019: The primer was developed by the ASDWA PFAS Workgroup to provide guidance and an overview of options and issues for state drinking water programs that are associated with testing for PFAS in water samples collected from public water systems. The document has been updated to include information about EPA’s new Method 537.1 that was published in November 2018. The primer is divided into eight topics on selecting an analytical method; finding a qualified laboratory; specifying a list of compounds and the form that each PFAS needs to be reported in; specifying reporting limits; technical issues that cause variability in testing results; sample collection procedures; interpreting results; and EPA’s ongoing work to develop new analytical methods.
  • ASDWA PFAS Water Utility Treatment Case Study – Town of Blades, Delaware – December 14, 2018:  This case study was developed for ASDWA by the Town of Blades, where high levels of PFOA and PFOS were found in their wells. The town worked with the state, EPA, and many partners to undertake subsequent actions to add GAC treatment and investigate the source of contamination. The case study includes information about their efforts; their treatment needs, considerations, and decisions; and the associated costs.
  • Download the ASDWA PFAS Fact Sheet – March 2019 that includes the information on this webpage in a 2-page PDF.

PFAS Background:  The understanding of potential drinking water impacts from PFAS has significantly increased over the past decade.  This class of chemicals started to get publicity in 2001 & 2002 due to water contamination from the Washington Works Plant located outside of Parkersburg, West Virginia, on the West Virginia/Ohio border.  The class-action lawsuit against DuPont due to water contamination at Little Hocking Water District and Lubeck Public Service District generated additional publicity.  In 2006, DuPont and other manufacturers such as 3M, agreed to principally phase out the production of PFOA and PFOS.

Third Unregulated Contaminant Monitoring Rule (UCMR3):  Due to escalating concerns, six PFAS compounds were included in EPA’s final UCMR3. UCMR3 monitoring occurred between January 2013 and December 2015 and included two to four quarterly samples at mostly large water systems throughout the country using EPA Method 537. As typical for the UCMRs, EPA regularly released the UCMR3 monitoring data, starting in late 2013.

EPA’s 2009 Provisional and 2016 Revised Health Advisories (HAs): In 2009, EPA established provisional health advisories (HAs) for PFOA at 400 parts per trillion (ppt) and for PFOS at 200 ppt; those two numbers were the benchmark at that time, even though an EPA health effects review was underway.  Based on the provisional health advisories, national occurrence in UCMR3 for PFOA and PFOS, at the time, appeared to be relatively low. In May 2016, EPA released revised HAs for the sum of PFOA and PFOS at 70 ppt. This numerical reduction significantly increased the number of water systems impacted.

UCMR3 Compound Name 2009 EPA HAs 2016 Revised HAs
PFOA Perfluorooctanoic acid 400 ppt 70 ppt (individual and combined sum with PFOS)
PFOS Perfluorooctanesulfonic acid 200 ppt 70 ppt (individual and combined sum with PFOA)
PFNA Perfluoroonanoic acid No HAs No HAs
PFHxS Perfluorohexanesulfonic acid
PFHpA Perfluoroheptanoic acid
PFBS Perfluorobutanesulfonic acid

2019 EPA PFAS Action Plan: Commitments by EPA in the action plan included:

  • Proposing a regulatory determination for PFOA and PFOS by the end of 2019.
  • Determining if a SDWA regulation is appropriate for a broader class of PFAS.
  • Including a larger group of PFAS in UCMR5.
  • Working through its regulatory development process for listing PFOA and PFOS as CERCLA hazardous substances.
  • Continuing to use its authority under TSCA to review new PFAS and issuing supplemental proposed Significant New Use Rules.
  • Finalizing the toxicity assessments for PFBS and GenX in 2019.
  • Developing draft toxicity assessments for PFBA, PFHxA, PFHxS, PFNA, and PFDA in 2020.
  • Developing guidance to facilitate cleanup of contaminated groundwater.
  • Developing new tools to characterize PFAS in the environment and materials to communicate about PFAS.

HAs Versus Regulatory Standards Create Challenges:  Use of HAs as guidance, versus a Safe Drinking Water Act (SDWA) regulation with an established Maximum Contaminant Level (MCL) creates challenges for state drinking water programs and public water systems. The HAs for PFOA and PFOS do not provide clarity on necessary actions for water systems to address the compounds, and how to communicate their actions and the associated health risks to the public.

State Regulatory and Oversight Challenges:  States are having to make tough decisions about whether or how to implement HAs and address PFAS in drinking water in the absence of federal standards. The table below shows the states that have proposed or established PFAS standards or guidelines that are lower or different than EPA’s HAs. These numbers demonstrate the variation in health risk goals and risk reductions among states in the absence of federal standards and are creating public confusion about what levels of PFAS are safe in drinking water.

State Drinking Water Action Compound Level (ppt)
California Interim Response Levels

Notification Levels


Sum of PFOA and PFOS






Connecticut Action Level Sum of PFOA, PFOS, PFNA, PFHxS, PFHpA 70
Massachusetts Proposed Groundwater Clean-up Standard

and Drinking Water MCL process initiation

Michigan Proposed Drinking Water MCLs PFOA














Minnesota Health Based Guidance for Water


Surrogate of PFOS HBV







New Hampshire Adopted Regulation 10/1/19 PFOA








New Jersey Adopted Regulation

Regulation in Development

Guidance Value







New York Rulemaking Initiated 7/8/19 PFOA




North Carolina Health Advisory GenX 140
Vermont Drinking Water Health Advisory Sum of PFOA, PFOS, PFNA, PFHxS, PFHpA 20

Click to expand the section below to see more examples of state efforts:

More PFAS Contamination Sites are Being Found:  The number of PFAS contaminated sites continues to grow. Over the past decade, PFAS contamination was found in many more locations beyond where the UCMR3 required water systems to conduct monitoring. Initially, contamination was thought to be somewhat limited to the chemical manufacturing facilities but has now expanded to include military bases, fire-fighting foam application, storage, and disposal sites, manufacturing sites of fire-retardant materials, landfills, and many other locations, including some that appear to be caused by air deposition. 


ASDWA PFAS Recommendations to EPA and CDC
ASDWA’s State Drinking Water Program Recommendations to EPA and CDC on PFAS (1/12/18) includes the following recommendations:

  • Form a working committee with ASDWA, EPA, CDC, and Department of Defense (DoD) leadership.
  • Develop a unified message and work with other stakeholders to minimize the potential adverse effects to public health and the environment.
  • Directly engage with states on any new federal actions and support current state efforts to consistently assess and address PFAS; and develop guidance for public water systems.
  • Conduct more health effects research and increase funding and support non-targeted analyses of drinking water for known and unknown PFAS, and substitute compounds.
  • Develop rules or guidance for other media (e.g., UIC, wastewater, soil leaching, air emissions).
  • Directly engage with stakeholders and industry to assess and address the universe of known and unknown PFAS compounds, and evaluate fire-fighting foam and alternatives.
  • Address laboratory and sampling needs for analytical methods and standards, lab vendors, standardization of lab results, and increase lab programs and capacity beyond UCMR3.

The Number of PFAS Being Manufactured Continues to Grow: The number of PFAS compounds that might be a cause of concern is thought to be in the hundreds and continues to grow. Since the phase-out of PFOA and PFOS, companies have shifted to “short-chain” PFAS such as GenX, which is now a significant concern in the Cape Fear Watershed downstream of a Chemours manufacturing plant in North Carolina. The increasing number of PFAS of concern is creating a host of data collection and analysis issues, as regulators and researchers are struggling to get enough robust health effects, analytical methods, and treatment data to make smart decisions.

For more information on how states are addressing PFAS, contact Deirdre White of ASDWA at


Download a PDF-version of this webpage.