PFAS Q&A: NFA Determinations for PFAS-Impacted Sites
Can you achieve a No Further Action (NFA) determination when soil and groundwater are impacted by PFAS?
Yes, under the right conditions, an NFA determination can be achieved even when PFAS is present in soil or groundwater, but success depends on selecting a strategy that aligns risk, practicality, and regulatory expectations. The critical early decision is whether a site truly requires extensive cleanup, or if a sequestration approach can adequately protect human health and the environment.
Full-scale PFAS treatment and removal remain technically challenging and costly. Soil excavation and long-term groundwater treatment systems can quickly escalate project budgets, especially as regulatory criteria tighten.
What is the best way to approach PFAS cleanup when seeking NFA determination?
Containment-focused approaches, such as capping, stabilizing, or isolating PFAS-impacted materials, may provide a practical path forward. These techniques are designed to keep impacted materials in place while preventing exposure, limiting migration, and maintaining long-term protection. When these strategies are supported by plausible conceptual site models and clear risk-based reasoning, they often reduce both cost and construction impacts compared to traditional remedial options.
It is vital to bring in a knowledgeable PFAS consultant early in the process to collaborate with regulators. Langan works closely with regulatory agencies, professional organizations, and clients to identify pain points related to evolving PFAS regulations and highlight recent findings and lessons learned. By engaging regulators before remedy selection is finalized, Langan can help align expectations, build trust, and position clients for approval of solutions that balance technical feasibility with environmental protection.
In short, NFA is achievable even when PFAS impacts remain on-site. For many properties, doing “less” isn’t cutting corners; instead, it’s choosing the strategy that best manages risk while avoiding unnecessary cleanup expenditures.
Jeff Ramey is a PFAS subject-matter expert with over 20 years of experience in the environmental industry. As Langan’s Wisconsin operations lead, he works with the Midwest team to grow the firm’s practice in the region and to support PFAS and forensic projects. His experience includes PFAS site characterization and investigation, remediation, analytical forensics, and risk management.
Scott Rademaker, PG, is a Senior Project Manager in Langan’s Milwaukee office with nearly 30 years of environmental consulting experience. His focus covers all aspects of environmental projects throughout the Midwest, including PFAS investigations, due diligence, property acquisition negotiations, remediation design, and regulatory site closure.