Small System PFAS Compliance: Doing More With Less
EPA’s 2024 NPDWR establishes the same PFAS MCL compliance obligation for a utility serving 10,000 people as for one serving 10 million—but the resources available to meet that obligation differ by orders of magnitude. Small and medium water systems (serving 3,300 to 100,000 customers) represent approximately 80% of US water utilities by number—and many of these systems face PFAS compliance challenges without dedicated environmental engineering staff, legal counsel, or capital access to match the treatment obligations being imposed. Practical, cost-effective compliance strategies are essential for these systems to meet the 2029 deadline without creating ratepayer unaffordability.
Step 1: Understand Your System’s PFAS Profile
Before selecting a treatment strategy, small systems must understand their specific PFAS challenge: which compounds are present, at what concentrations, from what sources, and with what seasonal variation. UCMR 5 monitoring data (required 2023–2025) provides the initial dataset, but systems with PFAS detections should conduct additional sampling at multiple points in the distribution system to identify whether PFAS come from source water or from within the distribution system (plumbing materials). Understanding the full PFAS compound profile—including short-chain compounds that GAC may not remove effectively—is essential for selecting appropriate treatment technology. PFAS consultant costs for initial system assessment ($10,000–$50,000) are well spent compared to the cost of installing wrong-sized or poorly-chosen treatment that fails to meet MCLs.
Funding Sources: Maximizing Available Assistance
Small and medium systems should aggressively pursue multiple funding streams: EPA/State DWSRF: Infrastructure Investment and Jobs Act (IIJA) provides $9 billion specifically for PFAS, with at least 25% reserved for small/disadvantaged systems; most state revolving funds offer low-interest loans and principal forgiveness grants for eligible systems. USDA Rural Development Water and Waste Disposal Program: Grants and loans for rural utilities serving populations under 10,000. ARPA Local Fiscal Recovery Funds: Remaining American Rescue Plan funds distributed to local governments can be applied to water infrastructure, including PFAS treatment. PFAS Litigation Settlements: Utilities that are eligible for 3M or DuPont MDL 2873 settlement distributions should file promptly—some small utilities have received settlement payments that substantially offset treatment costs. State grant programs: Michigan, New Hampshire, Maine, North Carolina, and several other states have state-specific PFAS water treatment grant programs for small utilities.
Technology Selection for Small Systems
For small systems, treatment technology selection should balance performance with simplicity of operation, since many small utilities lack dedicated water treatment operators. Most compatible technologies: Bagged/cartridge GAC systems: Simple to operate, lower capital cost, suitable for systems with moderate PFAS concentrations. Trade-off: higher media replacement frequency and cost per unit of water treated. Packaged treatment units: Pre-engineered GAC or IX systems sized for small system flow rates (50–500 gpm) offer simpler installation and reduced engineering costs. Interconnection to larger treated supply: Often overlooked—purchasing treated water from a neighboring compliant system may be more cost-effective than installing independent treatment for some small systems. Source water switching: If the system has access to alternative groundwater or surface water sources with lower PFAS, source switching may be more economical than treatment at the contaminated source.
Small system PFAS compliance is achievable—but requires proactive engagement with state agencies, creative use of available funding sources, and technology selection that matches operational complexity to available workforce capacity.