USEPA Granted Additional Stays to Review PFAS CERCLA Rule and NPDWR
On June 2, 2025, the U.S. Court of Appeals (USCA) for the District of Columbia (D.C.) granted a U.S. Environmental Protection Agency (USEPA) request for a 30-day extension (USCA Case #24-1193; Document #2118275) related to litigation contesting the designation of PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). USEPA designated PFOS, PFOA, and their salts and structural isomers as hazardous substances in April 2024 under CERCLA. The June 2 extension comes after a 30-day abeyance was granted on April 30, 2025 (USCA Case #24-1193; Document #2113719).
Additionally, on June 5, 2025, USEPA filed a request for a 45-day extension (USCA Case #24-1188; Document #2119400) related to the suit challenging PFAS regulations under the National Primary Drinking Water Regulation (NPDWR). The NPDWR for PFAS was issued by USEPA in April 2024 and set maximum contaminant levels (MCLs) for six PFAS in drinking water. USEPA requested the extension to allow incoming leadership additional time to become familiar with the regulation and associated case. The June 5 request comes after a 21-day extension (USCA Case #24-1193; Document #2115832) was granted on May 12, 2025.
USEPA Releases Eighth Set of UCMR5 Data
On June 2, 2025, USEPA released additional data collected under the fifth Unregulated Contaminant Monitoring Rule (UCMR 5). UCMR 5 requires sample collection by certain public water systems for 29 PFAS in drinking water between 2023 and 2025, including all six PFAS with MCLs. The UCMR 5 data released represents approximately 75% of the total data to be collected. Compliance with the PFAS National Primary Drinking Water Regulation is not required until April 2029, and therefore, UCMR 5 results are not indicative of compliance with applicable MCLs.
U.S. DoD Completes 99% of Planned PFAS PA/SIs; RI/FS Studies Continue at 574 Installations
In April 2025, the U.S. Department of Defense (DoD) released its FY2024 Report on Status of PFAS Preliminary Assessment/Site Inspection (PA/SI) Testing. As of the end of the 2024 fiscal year, PAs and SIs had been completed at 712 DoD installations (99% of installations requiring an assessment of PFAS use or potential releases). A PA focuses on reviewing existing information to identify potential contamination and determine if further study is needed, while a SI involves collecting new environmental data through sampling to confirm the presence, nature, and extent of contamination. The PA/SI findings indicate that 131 installations require no further action, whereas 574 installations are proceeding to the CERCLA remedial investigation/feasibility study (RI/FS) phase. A RI defines the nature, extent, and risks of contamination at a site, while a Feasibility Study FS develops and evaluates potential cleanup options to address the identified risks. Compared with the previous fiscal year, PA/SI completion progressed from 80% to 99% and NFA findings increased from 118 to 131 installations, and RI is underway or planned at 574 installations compared with 445.
Washington State Passes Legislation Requiring PFAS Testing of Biosolids
On May 17, 2025, Washington State Governor Bob Ferguson signed Senate Bill 5033 into law to require the Washington Department of Ecology (Ecology) to establish guidance by July 1, 2026, to clarify PFAS sampling requirements, including frequency and methodology, for facilities generating biosolids. Beginning in 2027, facilities generating biosolids will be required to sample and analyze for PFAS quarterly until mid-2028. Ecology is also charged with assembling an advisory committee of stakeholders, including farmers, toxicologists, soil amendment producers, and other interested parties, by 2028. Ecology and the advisory committee are charged with developing a report summarizing PFAS sampling and concentrations in biosolids in Washington by 2029.
Rhode Island Prohibits Manufacture and Sale of Consumer Products Containing PFAS, Requires PFAS Testing of Biosolids
In June 2025, Rhode Island Governor Daniel McKee signed House Bills 5019 and 5844 into law. House Bill 5019 (HB5019) bans the manufacture and sale of firefighting personal protective equipment (PPE) with intentionally added PFAS as of January 1, 2027. HB5019 also clarifies language originally in the Consumer PFAS Ban Act of 2024, which went into effect January 1, 2025. Clarified language includes requiring sellers to provide notification if current firefighter PPE contains PFAS, and more clearly defines consumer product categories, such as apparel, cosmetics, or textiles, which fall under the sales ban on consumer products with intentionally added PFAS. A second bill, House Bill 5844, requires quarterly testing of biosolids for PFAS starting in Q4 2025, with the first results due by the end of 2025. Additionally, starting on September 1, 2025, all biosolids producers within the state of Rhode Island must obtain approval from the Department of Environmental Management prior to the dispersal or application of biosolids.
Geosyntec PFAS Webinar Series
Geosyntec hosted a PFAS webinar series showcasing a thorough synthesis of the state of knowledge on the management of PFAS-impacted sites. Subject matter experts from Geosyntec and the broader stakeholder community discussed key PFAS technical, regulatory, and legal issues.
To view webinar recordings of this six-part PFAS series as well as other archived PFAS webinars, visit Geosyntec PFAS Webinar Series.
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If you have any questions or would like to discuss how PFAS may impact your business, please email pfas@geosyntec.com to be connected with one of our PFAS technical experts.
