PA

United States
Environmental Protection
Agency

Control of Per- and Polyfluoroalkyl
Substances Overview: A Qu ck
Reference Guide

Overview

Rule Title

Per- and Polyfluoroalkyl Substances (PFAS) National Primary Drinking Water Regulation
(NPDWR), 89 FR 32532, April 26, 2024, Vol. 89, No. 82

Rule Purpose

The PFAS Rule aims to improve public health protection by managing the health risks from PFAS
in drinking water.

Regulated
PFAS

The PFAS Rule regulates levels of perfluorooctanoic acid (PFOA), perfluorooctane sulfonic
acid (PFOS), perfluorohexane sulfonic acid (PFHxS), perfluorononanoic acid (PFNA),
hexafluoropropylene oxide dimeracid (HFPO-DAor GenX Chemicals), as well as mixtures of two
or more of PFNA, PFHXs, HFPO-DAand perfluorobutane sulfonic acid (PFBS) in drinking water.

Utilities
Covered

The PFAS Rule applies to all community water systems (CWSs) and non-transient non-
community water systems (NTNCWSs), hereafter referred to collectively as water systems.

Code of

Federal

Regulations

(CFR)

Citations

See the following sections in Title 40, Part 141 of the CFR:

~	For PFAS regulations, see Subpart Z.

~	For Maximum Contaminant Levels (MCLs), see 40 CFR 141.61 (c)(2).

~	For Maximum Contaminant Level Goals, see 40 CFR 141.50.

~	For compliance dates, see 40 CFR 141.6(1) and 40 CFR 141.900(b).

~	For Consumer Confidence Report (CCR) requirements, see Subpart O.

~	For Public Notification (PN) requirements, see Subpart Q.

Key Terms

Hazard Index (HI)

The Hazard Index is an approach that determines the health concerns associated with
mixtures of certain PFAS in finished drinking water. Low levels of multiple PFAS that
individually would not likely result in adverse health effects may pose health concerns when
combined in a mixture. The HI maximum contaminant level (MCL) represents the maximum
level for mixtures of PFHxS, PFNA, HFPO-DA, and PFBS allowed in water delivered by
a public water system. A HI MCL greater than 1 requires a system to take action (40 CFR
141,153(c)(3)(v)). (For a more technical definition of the Hazard Index, please see 40 CFR
141.2.)

Practical

Quantitation Level

(PQL)

The lowest level at which a contaminant can be reliably quantified within specific limits of
precision and accuracy during routine laboratory operating conditions using the approved
methods (89 FR 32573). The PQLs are used as part of determining compliance with the
PFAS MCLs. (This is different from a Practical Quantitation Limit, as defined at 40 CFR
141.2.)

Reliably and
Consistently (R&C)

Reliably and consistently below the MCL means that each of the samples contains regulated
PFAS concentrations below the applicable MCLs. For the PFAS Rule, this demonstration
of R&C below the MCL would include consideration of at least four quarterly samples at
an entry point below the MCL, but primacy agencies will make their own determination
as to whether the detected concentrations are R&C below the MCL (89 FR 32660-32661,
footnotes 21 and 23).

Trigger Levels

The trigger levels are used to determine an appropriate monitoring frequency and are set at
one-half of the MCLs for regulated PFAS, including the Hazard Index MCL for mixtures of
PFHxS, HFPO-DA, PFNA, and PFBS (see 141.902(a)(5)).

Public Health Benefits (89 FR 32533-32534)

Quantified
Benefits

Approximately $1.5 billion in quantifiable benefits per year, based on estimates of 9,614 fewer
deaths and 29,858 fewer illnesses in the decades following actions to reduce PFAS levels,
including fewer cancers, lower incidence of heart attacks and strokes, and reduced birth
complications.

Nonquantifiable
Benefits

Reductions in adverse impacts to immune systems, thyroid disease, impacts to human
endocrine systems, liver disease, and negative reproductive effects such as decreased fertility.


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v>EPA

United States
Environmental Protection
Agency

S

Control of Per- and Polyfluoroalkyl
Substances Overview: A Quick
Reference Guide

Key Milestones

Timeframes For Water Systems (see 40 CFR 141.6(1) and 40 CFR 141.900(b)):

June 25, 2024

Beginning on this date, analyses for regulated PFAS must only be conducted by laboratories
that have been certified by the EPA or the primacy agency. Also, by this date, water systems
must report data for concentrations as low as the trigger levels.

April 26, 2027

Initial monitoring results are due to primacy agencies, and compliance monitoring begins.
CCR requirements, PN requirements associated with monitoring violations, and Reporting
and Recordkeeping requirements take effect.

April 26, 2029

All regulated water systems must comply with the PFAS MCLs and begin to issue PN for MCL
violations.

Timeframes for Primacy Agencies (see 40 CFR 142.12(b)):

By April 27, 2026

Agencies seeking primacy must submit a final primacy application to the EPA or submit a
request for an extension.

By April 26, 2027

Primacy agencies must determine the compliance monitoring schedule for regulated water
systems. Primacy agencies also begin to issue monitoring and reporting violations.

By April 26, 2028

Agencies with an approved primacy application extension must submit a final program
revision package to the EPA.

April 26, 2029

Primacy agencies begin to issue MCL violations.

June 25, 2024

Analyses for regulated PFAS must only be
conducted by laboratories that have been
certified by the EPA or the primacy agency.
Also, water systems must report data for
concentrations as low as the trigger levels.

For Drinking Water Systems

April 26, 2027

~	Initial monitoring requirements
provided to primacy agencies.

~	Compliance monitoring begins.

~	CCR requirements, PN
requirements associated with
monitoring violations, and
Reporting and Recordkeeping
requirements take effect.

April 26, 2029

All regulated water
systems must comply
with the PFAS MCLs
and begin to issue PN
for MCL violations.

I April 27, 2026

Submit final primacy
application to the
EPA or submit
a request for an
extension.

April 26, 2027

Determine the
compliance monitoring
schedule for regulated
water systems. Begin
to issue monitoring and
reporting violations.

i April 26, 2028

Agencies with
approved extension,
submit final program
revision package to
the EPA.

i April 26,
2029

Begin to
issue MCL
violations.

Regulatory Thresholds

The following are the PFAS MCLs, MCLGs, Trigger Levels, PQLs, and the number of significant figures to which
sampling results are rounded:

Compound

MCL

MCLG

Trigger Level

PQL1

Significant
Figures (in
Trigger Levels
and MCLs)

Level (in parts per trillion, unless otherwise noted)

PFOA

4.0

Zero

2.0

4.0

Two

PFOS

4.0

Zero

2.0

4.0

Two

PFHxS

10

10

5

3.0

One

PFNA

10

10

5

4.0

One

HFPO-DA

10

10

5

5.0

One

PFBS

N/A

N/A

N/A

3.0

N/A

Hazard Index2
(mixtures containing two
or more of PFHxS, PFNA,
HFPO-DA, and PFBS)

1 (unitless)

1 (unitless)

0.5 (unitless)

N/A

One

1	All PQLs have two significant figures.

2	Rounding of the HI only occurs at the end of the overall calculation. See the Per- and Polyfluoroalkyl Substances
Hazard Index: A Quick Reference Guide for more details.

Sources: MCLs are listed in 40 CFR 141.61(c). MCLGs are listed in 40 CFR 141.50. Triqger levels are listed in 40
CFR 141.902(a)(5). PQLs are listed in 40 CFR 141.903(f)(iv).

v * -


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Control of Per- and Polyfluoroalkyl
Substances Overview: A Qu ck
Reference Guide

Laboratory Information and Analytical Methods for Regulated PFAS
(40 CFR 141.900(b)(1) and 40 CFR 141.901)	

~	For all samples used to satisfy initial monitoring and compliance monitoring requirements, laboratories must
use either EPA method 533 or EPA method 537.1, version 2.0.

~	On June 25, 2024, a requirement to use laboratories certified by the EPA or the primacy agency went into
effect. In addition, all samples analyzed beginning on that date must have regulated PFAS data reported to
concentrations as low as the trigger levels.

Best Available Technologies (BATs) and Small System Compliance
Technologies (SSCTs) (40 CFR 141.61(d) and 40 CFR 141.61(e))

~	The BATs identified for regulated PFAS are anion exchange, granular activated carbon (GAC), reverse osmosis
(RO), and nanofiltration (NF).

~	The EPA identifies feasible BATs based on factors such as high removal efficiency, reasonable cost, service life
and ability to achieve compliance.

~	The SSCTs are RO/NF for water systems that serve more than 3,300 persons, as well as anion exchange and
GAC for all size categories.

~	There is no federal requirement for a system to use the EPA-identified BATs or SSCTs; however, individual
primacy agency requirements may vary.

Monitoring Schedules and Requirements (40 CFR 141.902)

Sampling is required at each entry point to the distribution system (entry point) during normal operating conditions.
An interconnection between two systems that transmits finished water is not considered an entry point.

Sampling
Frequency

Eligibility Requirements

Sample Timing Requirements

Initial Monitoring1 (40 CFR 141.902(b)(1))

Semiannual

Groundwater CWSs and NTNCWSs serving 10,000 or fewer
persons

Two consecutive samples per
entry point within a 12-month
period, unless the exception
below applies.23 Samples must
be taken five to seven calendar
months apart.

Quarterly

All other CWSs and NTNCWSs, including:

~	All surface water systems

~	All groundwater under direct influence (GWUDI) systems

~	Groundwater systems serving more than 10,000 persons

~	Any entry point that blends surface water and groundwater

~	Water systems that change the source water type
seasonally

Four consecutive quarters of
samples per entry point within
a 12-month period, unless the
exception below applies.2-3
Samples must be taken two to
four calendar months apart.

1	Previously acquired data collected on or after January 1, 2019, can be used to meet some or all of the initial
monitoring requirements if PFAS Rule requirements are met (for example, samples must be analyzed using
approved methods).

2	If a system has some previously collected results meeting PFAS Rule requirements, but less than necessary to
meet the initial monitoring requirements, the system can supplement with additional monitoring events such that all
required calendar periods are represented, regardless of the year. See 40 CFR 141.902(b)(1)(viii).

3	If a system has multiple years of data, the most recent data must be used.

Compliance Monitoring (40 CFR 141.902(b)(2))

Quarterly

Required at an entry point for all regulated PFAS if any of the

following apply:

~	Any regulated PFAS concentration met or exceeded a
trigger level during initial monitoring at that location.

~	An individual sampling point has been monitored quarterly
during compliance monitoring and a primacy agency has not
made a determination that all levels of regulated PFAS at
the entry point are R&C below the regulated PFAS MCLs.

~	An individual sampling point on triennial monitoring detects
regulated PFAS at concentrations that meet or exceed a
trigger level. The sample that met or exceeded a trigger
level is considered the first quarterly sample.

~	An individual sampling point on annual monitoring has
sampling results with any regulated PFAS concentrations
that meet or exceed an MCL or that the primacy agency
determines make it ineligible for an R&C determination. The
sample that triggers the requirement for quarterly monitoring
is considered the first quarterly sample.

Samples must be collected
on dates designated by
the primacy agency, in four
consecutive calendar quarters.


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v>EPA

United States
Environmental Protection
Agency

Control of Per- and Polyfluoroalkyl
Substances Overview: A Quick
Reference Guide

Monitoring Schedules and Requirements (40 CFR 141.902) Cont.

Compliance Monitoring (40 CFR 141.902(b)(2))

Annual

A primacy agency may allow annual sampling at an entry point if:
~ The primacy agency determines that all regulated PFAS
concentrations at the entry point are R&C below PFAS
MCLs, after considering, at a minimum, four consecutive
quarterly compliance monitoring samples.

Samples must be collected at a
time designated by the primacy
agency, in the quarter in which
detected concentrations were
highest during the most recent
round of quarterly monitoring.

Triennial

A primacy agency may allow triennial monitoring at an individual
entry point if any of the following apply:

~	At the start of the compliance monitoring period, if all initial
monitoring results contain concentrations of all regulated
PFAS below trigger levels.

~	The most recent three consecutive annual monitoring
results each demonstrate concentrations of all regulated
PFAS below trigger levels.

~	The previous sample collected triennially demonstrates all
regulated PFAS concentrations are below trigger levels.

Note: After beginning compliance monitoring, a system may
not transition directly from quarterly monitoring to triennial
monitoring.

Samples must be collected at a
time designated by the primacy
agency, in the quarter in which
detected concentrations were
highest during the most recent
round of quarterly monitoring
(or semi-annual sampling,
if no quarterly sampling has
occurred).

Compliance monitoring frequency for the next monitoring period changes for:

~	Entry points being sampled triennially:

~	If a concentration of any regulated PFAS is greater than or equal to the trigger level, the system is
required to begin quarterly monitoring.

~	Entry points being sampled annually:

~	If the system has three consecutive samples with all regulated PFAS at levels below the trigger levels,
the primacy agency may allow the system to begin triennial monitoring.

~	If a sample result meets or exceeds a PFAS MCL or the primacy agency determines the entry point is no
longer R&C below the MCLs for PFAS, the system must begin quarterly monitoring.

~	Entry points being sampled quarterly:

~	Sampling frequency may change to annually when all regulated PFAS are deemed R&C below the MCLs
by the primacy agency.

\

Violations (40 CFR 141.905 and Appendix A to Subpart Q of Part 141)

Monitoring and Testing Violations

~ Beginning April 26, 2027, each failure to monitor in accordance with applicable requirements is a monitoring
violation.

MCL Violations

~ Compliance with the MCLs must be determined, beginning April 26, 2029, based on the analytical results
obtained at each entry point. If one entry point is in violation of an MCL, the system is in violation of the MCL.

Reporting Violations

~ Failure to submit monitoring data in accordance with applicable requirements, beginning April 26, 2027,
and failure to notify the primacy agency following a MCL violation, beginning April 26, 2029, are reporting
violations.

PN and CCR Rule Requirements Applicable to Regulated PFAS
(Subparts O & Q of Part 141)

The final rule established PN tiering for systems In violation of the requirements in Subpart Z and established
mandatory health effects statements to communicate potential health concerns to drinking water consumers in
the PN and CCRs.

Beginning April 26, 2027, systems with a PFAS monitoring and testing violation in 40 CFR 141.905(c) must
provide notice to consumers no later than one year after the system learns of the violation. Beginning April
26, 2029, systems that have a PFAS MCL violation must provide PN as soon as practical, but no later than 30
days after a system learns of the violation.

Beginning with CCRs delivered by July 1, 2027, all CWSs must include information in the reports on detected
PFAS contaminants and compliance information related to requirements in Subpart Z. according to 40 CFR
141.153.

m ¦

A


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v>EPA

United States
Environmental Protection
Agency

Control of Per- and Polyfluoroalkyl
Substances Overview: A Quick
Reference Guide



For additional
information on the
PFAS Rule

Please visit the EPA PFAS
NPDWR Implementation
Web site at https://www.eDa.
aov/dwreainfo/pfas-rule-
implementation or contact
your drinking water primacy
agency.

Note: The statutory
provisions and the EPA
regulations described
in this document
contain legally binding
requirements. This
document is not a
regulation itself, nor does
it change or substitute
for those provisions and
regulations.

Office of V\Mer (4606M)	EPA810-F-24-047	httei%ater.epa.gov/drink	December 2024


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