PFAS Q&A: NFA Environmental Determinations for PFAS-Impacted Sites
PFAS contamination can create challenges for environmental remediation as regulatory standards evolve and cleanup methods remain costly and complex. However, the presence of PFAS in soil or groundwater does not necessarily prevent a site from achieving a No Further Action determination.
Langan’s PFAS experts Jeff Ramey and Scott Rademaker discuss what property stakeholders should know about NFA determinations and how PFAS consultants can help.
Key Takeaways
- An environmental NFA determination is a formal document from a governmental agency that states when a property site requires no additional investigation or remediation.
- NFA can be achievable even when PFAS remains on-site and complete removal may not be necessary to protect human health and the environment.
- Regulators will consider site-specific factors when evaluating a PFAS-impacted property, including specific PFAS concentrations, potential migration pathways, and what the land is used for.
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.
How can PFAS consultants help achieve an NFA determination?
Navigating an NFA determination for a PFAS-impacted site requires more than selecting a PFAS remediation method. 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.
Contact Langan’s PFAS experts to discuss your site and determine the right path toward an NFA determination.
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.
NFA Environmental Determination FAQs
What is an NFA determination letter?
An NFA determination is a formal document from a governmental environmental agency stating that a property site has been checked or cleaned up, and that no additional investigation or remediation is required. Achieving an NFA does not always mean that impacted material has been removed, and in some cases contamination can remain in place if it is appropriately managed and does not pose a risk to human health or the environment.
How long does it take to get an NFA determination?
The timeline for achieving an NFA determination varies based on jurisdiction, site conditions, the extent of contamination, and investigation or remediation requirements. Early coordination with regulators can help clarify potential timelines for your site.
How much does it cost to pursue an NFA determination?
The cost of an NFA determination depends on the size and complexity of the site, the extent of the contamination, and site investigation needs. Developing a site-specific strategy can help stakeholders avoid unnecessary remediation costs.
What factors do regulators consider when evaluating an NFA determination for a PFAS-impacted site?
Regulators may consider a range of site-specific factors when evaluating a PFAS-impacted property for a NFA determination, including PFAS concentrations in soil and groundwater, potential migration pathways, and current or future land use. A well-designed 3D conceptual site model can provide the framework for information on PFAS sources, paths of travel, and the potential people or ecosystems at risk at a particular site. This visualization can help demonstrate to regulators whether PFAS impacts can be managed and what remediation, if any, may be required.
Do NFA requirements vary by state?
Yes, NFA requirements can vary significantly by state, including investigation standards, cleanup criteria, and site documentation. For PFAS-impacted properties, regulatory requirements continue to evolve, making it important for stakeholders to understand any changes that may apply to that site’s jurisdiction.
What happens after an NFA determination is issued?
After an NFA determination is issued, no additional investigation or remediation is required. Some sites may require continuous monitoring or compliance with land-use restrictions. Property stakeholders should retain documentation and understand any continuing requirements associated with the NFA.
Can an NFA determination be revisited if PFAS regulations change?
Yes, an NFA determination may be revisited as PFAS regulations evolve. An NFA is issued based on existing information about site conditions, contaminants of concern, and regulatory requirements considered at the time the determination is made. If new information becomes available or PFAS requirements change, a site may be reopened for investigation.