The U.S. Environmental Protection Agency (EPA) outlined several PFAS-related actions in its Spring 2025 Unified Regulatory Agenda (published September 4, 2025) that could affect how biosolids are managed and land-applied. While not all changes are final, the direction points to increased scrutiny, more monitoring, and potentially tighter controls where PFAS are present.
Why This Matters in Virginia:
Virginia relies on land application as a cost-effective, beneficial way to recycle nutrients to soil. If federal rules expand PFAS monitoring and reporting, Virginia utilities, haulers, and farmers may see changes in testing requirements and recordkeeping.
Key Developments to Watch:
- Toxics Release Inventory (TRI) Addition (final action anticipated late 2025)
- EPA’s additions expand reporting and public transparency around PFAS use and releases. EPA has already added PFHxS Na to TRI (October 7).
- Implications: Greater visibility into PFAS may influence how biosolids programs manage community communications and upstream industrial contributions.
- Effluent Limitations Guidelines (ELGs) for PFAS Manufacturers (new proposals expected January 2026)
- Although a prior proposal was withdrawn, new ELGs targeting PFAS manufacturers could reduce PFAS entering wastewater streams upstream.
- Implications: Potentially fewer PFAS for downstream wastewater treatment and biosolids management.
- Withdrawal of Certain PFAS Regulatory Determinations (proposed, possibly by February 2026)
- EPA is considering withdrawing regulatory determinations for specific PFAS.
- RCRA Hazardous Constituents Listing (final rule expected April 2026)
- EPA may add specific PFAS to the Resource Conservation and Recovery Act (RCRA) list of hazardous constituents.
- NPDES Permit Updates (expected May 2027)
- EPA plans to include PFAS on the National Pollutant Discharge Elimination System (NPDES) list of pollutants, triggering required monitoring and reporting in permitted discharges.
- Drinking Water Standards (timing extended)
- EPA intends to retain current standards for PFOA and PFOS but extend compliance dates.
Bottom Line:
EPA’s regulatory agenda signals increasing attention to PFAS in wastewater and biosolids systems. For Virginia, the likely outcome is more monitoring, more transparency, and potentially tighter management practices where PFAS are present—while continuing to support safe, beneficial land application of biosolids.