In November, the EPA announced significant actions to address PFAS (per- and polyfluoroalkyl substances) in the environment. First, the Office of Water issued a memorandum from the PFAS National Pollutant Discharge Elimination System (NPDES) Regional Coordinators Committee outlining an “Interim Strategy for Per- and Polyfluoroalkyl Substances in Federally Issued National Pollutant Discharge Elimination System Permits.” The recommendation is that PFAS-related conditions be included in NPDES permits issued to municipal, industrial and MS4 entities. PFAS recommendations are for a phased approach to monitor direct discharges where PFAS compounds are expected to be present, with the “expected presence” broadly defined.

The EPA also recommends that appropriate best management practices (BMPs) be included in permits to control or abate the discharge of PFAS. The recommendation is specific to the few states where EPA has permitting authority, including Massachusetts, New Hampshire, New Mexico, D.C., Native American lands, Puerto Rico, and certain federal facilities. States with permitting authority may follow EPA’s lead. In addition, the new wastewater analytical method is anticipated to be finalized in 2021, which will help streamline monitoring PFAS in wastewater. The new administration is expected to continue to prioritize PFAS and may designate the contaminants as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

2021 PFAS funding outlook
As we head into 2021, substantial PFAS funding has been proposed in Senate draft spending bills for a wide variety of research, regulatory activity and remediation. Spending priorities include:


  • Regulatory actions and researchto move forward with developing maximum contaminant levels (MCLs).
  • Direct support to states and tribes for remediation and cleanup, and information outreach.
  • Prioritizing applications for Water Infrastructure Finance and Innovation Act (WIFIA) financing for PFAS projects.

EPA and Department of Energy (DOE)

  • Collaborate using supercomputing for computational toxicology studies.

Department of Defense

  • Remediation, aqueous film forming foam (AFFF) replacement and personnel exposure.


  • Determine whether PFAS chemicals allowed for use as a food contact substance continue to meet safety standard of reasonable certainty of no harm.

“There is substantial PFAS activity at the federal level currently and PFAS activity is anticipated to increase with the new administration.”

Dan Stanaway, Senior Hydrogeologist

About the experts

Dan Stanaway is a Senior Hydrogeologist in Brown and Caldwell’s Grand Rapids, Michigan, office. Dan has a decade of experience in the mining industry assisting clients as they navigate the compliance and permitting process.

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