With EPA’s April 2024 final PFAS MCL rule establishing a 4 ppt limit for PFOA and PFOS and simultaneous hazard index limits for four additional compounds, water utilities face a concrete compliance deadline backed by enforcement authority. Procurement officers tasked with evaluating treatment system bids are navigating a market that has expanded rapidly—and unevenly—in both vendor offerings and technical claims. A structured evaluation framework separates defensible procurement decisions from costly mistakes.
Key Technical Criteria That Should Appear in Every RFP
Every request for proposals (RFP) for PFAS treatment equipment should require vendors to provide performance data from pilot or full-scale installations treating source water chemically similar to the procuring utility’s supply. Performance claims based solely on clean-water laboratory tests without NOM competition are not meaningful for surface water utilities. Specify that performance data must cover the full regulated PFAS suite under EPA Method 533 or 537.1, not just PFOA and PFOS.
EBCT, superficial velocity, and influent PFAS concentrations must be clearly stated alongside any removal efficiency claim. A vendor claiming “99% PFAS removal” at an EBCT of 30 minutes in clean groundwater is making a very different claim than one demonstrating 95% removal at 10 minutes EBCT in NOM-laden surface water. Require vendors to provide breakthrough curve data showing performance through at least 10,000 bed volumes under realistic conditions.
Short-chain PFAS performance data—specifically for PFBS (C4) and PFHxA (C6)—must be explicitly requested. Bids that only report PFOA and PFOS removal should be viewed skeptically, as omission of short-chain data may conceal significant performance gaps that will create compliance problems in the first year of operation. The EPA MCL rule’s hazard index provisions mean that short-chain PFAS contribute to regulatory liability even when their individual concentrations are below single-compound MCLs.
Lifecycle Cost Analysis and Vendor Due Diligence
Capital cost comparisons between competing bids must be normalized to the full lifecycle cost per million gallons treated to compliance. This requires vendors to estimate media service life (bed volumes to breakthrough at the worst-case seasonal source water quality), media unit cost, change-out labor, transportation, and disposal or reactivation fees. Procurement officers should request that vendors provide these estimates in a standardized format to enable direct comparison.
Vendor financial stability and supply chain resilience deserve scrutiny given the scale of PFAS treatment infrastructure investment required nationally. Preferred vendors should be able to demonstrate domestic or diversified media manufacturing capacity, service contracts with performance guarantees, and track records of multi-year media supply commitments. A bid from a new entrant offering dramatically lower unit media costs warrants additional due diligence to confirm that long-term supply can be sustained at the quoted price.
Finally, procurement officers should require vendors to address end-of-life media management in their bids. Spent PFAS-laden media is a regulated waste in many states, and disposal cost and liability represent a significant component of lifecycle cost that is sometimes omitted from initial bid proposals. A complete bid should include either a documented disposal pathway with a licensed facility or a demonstrated thermal destruction process with regulatory approval for PFAS waste.