Project sites that are in or joining one of the Minnesota’s remediation programs, such as the Minnesota Pollution Control Agency’s (MPCA) Brownfields program or Superfund program, may find themselves subject to more sampling and investigation as a result of the MPCA’s PFAS Monitoring Plan.

The new PFAS Monitoring Plan, released on March 22, 2022, outlines Minnesota’s plans to monitor for per- and polyfluoroalkyl substances, or PFAS, under a variety of programs run by MPCA, including the state’s remediation programs. The MPCA program staff will be evaluating the need for PFAS sampling at new and active sites. The primary factors for the evaluation:

  • Historical and current site usage
    The MPCA will review a site’s current and historical usages to determine if it included processes that may have or currently involve the use of PFAS. Historical site activities such as electroplating, petroleum refining, application of nonstick and/or waterproof coatings, and commercial printing, will raise questions about past PFAS use and releases to the environment.
  • Proximity to PFAS impacts
    Sites will be evaluated that are near locations with known PFAS detections or potential release sites, such as places where fire training occurred or dumps/landfills.

The MPCA will require responsible parties in the Superfund program to sample for PFAS based on the evaluation factors above. Non-responsible parties in voluntary remediation programs may also be required to sample for PFAS depending on the site and regulatory assurances requested. The sampling results are to be compared to existing health-based guidance or Minnesota Department of Health health risk limits values for appropriate media. The MPCA intends to address potential remedial action of PFAS exceedances under the existing Minnesota Environmental Response and Liability Act, and the issuance of liability letters and/or closure will be dependent upon the performance of the remedial strategies.

At this time, the MPCA has not incorporated PFAS into its existing guidance documents; however, the agency is in the process of developing more detailed PFAS-specific guidance. The MPCA expects to have the guidance documentation available in 2023. The results of the initial PFAS monitoring will also be used to inform the development of those documents.

The MPCA intends to begin implementing these additional PFAS sampling requirements for sites entering the MPCA’s remediation programs, as well as at existing sites. Existing sites under the Superfund program will be required to assess PFAS as part of the five-year review process.


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This post is the third in a series looking at each of the monitoring programs outlined in the new PFAS Monitoring Plan released by the MPCA. For insight into the overall plan and what facilities the MPCA identified initially as affected, see the other posts in the series: 

Catherine Stott, PE, PG, is an associate environmental engineer at Burns & McDonnell with over 20 years of experience as an engineer, hydrogeologist and project manager. She specializes in environmental investigation and remediation, litigation support, and estimating future environmental costs.