Understanding PFAS Regulations in Illinois

Per- and polyfluoroalkyl substances (PFAS) have come under increasing scrutiny in Illinois due to their persistence in the environment and potential health impacts. Often referred to as “forever chemicals,” PFAS are synthetic compounds found in consumer products, firefighting foams, industrial waste, and contaminated drinking water. As public awareness grows, so too does the demand for regulatory oversight and environmental due diligence related to PFAS in the state. 

Illinois has taken a proactive approach to responding to PFAS contamination by integrating science-based standards, expanding monitoring programs, and implementing interim guidance for environmental professionals. While the state currently aligns with federal guidance, it has also introduced its own requirements and action levels for PFAS in drinking water, soil, and groundwater to safeguard public health and the environment. Property owners, developers, and municipalities are encouraged to stay abreast of these evolving regulations to manage risk and ensure compliance. 

Recent Updates to Illinois PFAS Regulations 

In January 2023, Illinois introduced new amendments to its Environmental Protection Act, enhancing its authority to monitor and regulate PFAS contamination. Through the Illinois Environmental Protection Agency (IEPA), the state expanded its PFAS Investigation Network to identify contamination sites and launched a multi-phase sampling initiative targeting public water supplies. These efforts align with the broader national movement led by the U.S. EPA, but with added state-specific focus on vulnerable communities and high-exposure zones. 

Additionally, Illinois adopted enforceable Health-Based Guidance Levels (HBGLs) for five key PFAS compounds. While not formal Maximum Contaminant Levels (MCLs), these HBGLs inform mitigation actions and risk evaluations for water utilities, private well users, and environmental consultants. Illinois also requires that any newly discovered PFAS discharges be reported under the Illinois Pollutant Discharge Elimination System (NPDES), further tightening its regulatory framework around legacy and active contamination. 

Here are additional Illinois PFAS Regulatory compliance deadlines and milestones:

• April 1, 2029: Federal MCLs for PFAS compounds will be fully enforced in all public water systems
• June 30, 2026: Expected completion of statewide PFAS assessment in public water systems
• January 1, 2024: Enhanced focus on vulnerable communities and high-exposure zones implemented
• July 1, 2023: Multi-phase sampling initiative targeting public water supplies began
• March 15, 2023: Implementation of requirement that newly discovered PFAS discharges be reported under the Illinois Pollutant Discharge Elimination System
• January 1, 2023: New amendments to the Environmental Protection Act enhanced authority to monitor and regulate PFAS
• September 1, 2021: IEPA expanded its PFAS Investigation Network to identify contamination sites
• June 15, 2021: Illinois adopted Health-Based Guidance Levels (HBGLs) for five key PFAS compounds
• January 1, 2020: IEPA launched its Community Water Supply Sampling Project

How Partner Can Help

Partner’s Illinois team brings specialized knowledge of the state’s emerging PFAS regulatory framework and Health-Based Guidance Levels. Our Illinois-licensed environmental professionals conduct thorough Phase I & II Environmental Site Assessments (ESAs) specifically designed to identify potential PFAS sources in accordance with IEPA guidelines and the Illinois PFAS Network’s recommendations. We employ sampling methodologies capable of detecting the full spectrum of PFAS compounds at the state’s increasingly stringent thresholds. 

When contamination exceeds Illinois’ guidance levels, our remediation experts develop strategies that achieve compliance while navigating the state’s site remediation program requirements. Partner’s engineers and scientists have extensive experience with Illinois’ diverse geological conditions—from the sandy soils of northern Illinois to the tight clay formations elsewhere—implementing effective remediation approaches tailored to local conditions. We manage all IEPA reporting requirements and coordinate with relevant stakeholders, providing comprehensive support throughout the assessment and remediation process while emphasizing cost-effective solutions.

Frequently Asked Questions

Are PFAS regulated in Illinois drinking water systems?

Yes. The Illinois EPA has issued Health-Based Guidance Levels for several PFAS compounds in drinking water. While these are not yet enforceable MCLs, water systems must report exceedances and may be required to take action to reduce exposure. Utilities are also encouraged to implement monitoring and treatment technologies, particularly in communities where sampling has identified PFAS above guidance thresholds.

Do real estate transactions in Illinois require PFAS due diligence?

While not yet a formal requirement, PFAS considerations are increasingly becoming part of Phase I Environmental Site Assessments (ESAs) in Illinois, especially in transactions involving industrial or firefighting-related properties. The IEPA’s ongoing investigations and the potential for future liability are encouraging investors and lenders to factor PFAS risks into their environmental due diligence process. Partner Engineering and Science provides PFAS sampling, risk analysis, and compliance guidance as part of our site assessment services in Illinois.