Persistent Chemicals/U.S. Department of Energy Should Complete Efforts to Review PFAS Use: U.S. Government Accountability Office Report

The United States Government Accountability Office (“GAO”) issued a September 10th report titled:

PERSISTENT CHEMICALS: DOE Should Complete Efforts to Review PFAS Use (“Report”).

See GAO-25-107809.

The GAO states that

• Certain per- and polyfluoroalkyl substances (“PFAS”) have been associated with negative impacts to human health and the environment.
• United States Department of Energy (“DOE”) sites across the country have used PFAS for a variety of purposes, including:
  • Firefighting.
  • Uranium enrichment.
• The United States Environmental Protection Agency (“EPA”) established legally enforceable maximum contaminant levels (“MCLs”) for six PFAS in drinking water and designated two of them PFOA and PFOS as hazardous substances under Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”) (In May 2025, EPA leaders announced that they plan to rescind the MCLs for several types of PFAS but intend to keep the MCLs for PFOA and PFOS).
• DOE sites with on-site drinking water systems are expected to need to comply with the EPA’s rules.
• GAO was asked to review DOE’s cleanup of PFAS.

The GAO Report examines:

• Laws and regulations relevant to cleanup efforts.
• DOE’s cleanup plans.
• Identification, disposal, testing, and cleanup of PFAS contamination.
• DOE’s spending on PFAS-related efforts; and estimated future costs.

GAO examined nine DOE sites selected to represent a variety of offices and locations with PFAS contamination.

GAO describes its “Key Takeaways”:

• According to a survey of 57 DOE sites, 20 of these sites have completed an initial review to identify historical and current PFAS use, 21 sites have reviews in progress, and 16 have not started. Additionally, over 100 DOE sites were not surveyed and therefore their actions to review historical PFAS use are unknown.
• 17 of the 57 surveyed DOE sites have on-site drinking water systems, and they have all tested these systems for certain PFAS and 3 reported PFOA or PFOS in drinking water that exceeded federal MCLs of 4.0 ppt.
• DOE does not routinely include PFAS cleanup costs in its estimates of future cleanup costs such as environmental liabilities, because according to DOE officials, these costs are not yet sufficiently known to report under federal accounting standards.

GAO recommends that DOE:

…direct all its sites that have not completed an initial historical and current use review of PFAS to do so by an established deadline and report to the heads of each responsible DOE office on if additional investigation, characterization, or cleanup of PFAS contamination is needed.

A copy of the GAO Report can be downloaded here.