New interim strategy will address PFAS through certain EPA-issued wastewater permits

December 4, 2020

The U.S. Environmental Protection Agency announced on November 30 two important steps to address per- and polyfluoroalkyl substances (PFAS).

First, the EPA issued a memorandum detailing an interim National Pollutant Discharge Elimination System (NPDES) permitting strategy for addressing PFAS in EPA-issued wastewater permits. Second, the EPA released information on progress in developing new analytical methods to test for PFAS compounds in wastewater and other environmental media.

Together, the actions provide for federally enforceable wastewater monitoring for PFAS that can begin as soon as validated analytical methods are finalized.

PFAS have been found in treated wastewaters and identified as a stormwater pollutant in urban, residential, commercial, and industrial settings. Both treated wastewater and stormwater are resources used to support managed aquifer recharge, a priority of NGWA.

Specific strategy recommendations include:

  • Permit requirements for phased-in monitoring and best management practices considering when point source wastewater discharges are expected to have PFAS
  • Permit requirements for phased-in monitoring and stormwater pollutant control considering when stormwater discharges are expected to have PFAS
  • Information sharing on permitting practices, development of a permitting compendium, and an information sharing platform.

NGWA CEO Terry S. Morse, CAE, CIC, issued the following statement in response to the NPDES PFAS: Interim Strategy for PFAS in Federally Issued National Pollutant Discharge Elimination System Permits.

“We at NGWA are encouraged by the PFAS NPDES Regional Coordinators Committee’s new interim strategy to better understand and mitigate the risk in PFAS in wastewater and stormwater discharge.

“As future strategies and guidance are drafted, NGWA urges the EPA and its partners to be thoughtful of how PFAS transmissions from wastewater and stormwater into our nation’s surface water in turn affect our groundwater supply.

“The United States — and the world — is highly dependent on groundwater as a source of clean drinking water and for crop irrigation. PFAS contamination in groundwater must be a top priority for future study and actions by the EPA.”

At least an estimated 1525 municipal separate storm sewer system (MS4) NPDES permittees may be coincident with a groundwater-supplied public community water system (CWS), which, collectively, serve 36.4 million people.

Thirty states have from 20 percent to 100 percent of their MS4 permittees that are coincident with groundwater-supplied community water systems. These percentages and populations may increase if surface-water supplied CWSs with backup groundwater wells and separately regulated industrial permittees were included.

NGWA and its Stormwater Review Group have been active in encouraging the EPA to address municipal and industrial disposal of stormwater by subsurface infiltration methods that may potentially impact groundwater quality. Comments addressed the needs of both private well owners and small community groundwater systems.

  • In November and December 2019, NGWA’s Stormwater Review Group stated to the EPA’s Environmental Financial Advisory Board that stormwater was a resource for water supply, but if contaminated and infiltrated to the subsurface, required EPA design guidance that protected groundwater quality, including monitoring of infiltration sites before funding construction.
  • On May 1, 2020, the NGWA Stormwater Review Group commented on the “Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity” indicating potential problems with industrial stormwater infiltration carrying PFAS and other chemicals to groundwater.
  • On September 3, 2020, NGWA commented on the EPA’s “State Formula Allocations for Sewer Overflow and Stormwater Reuse Grants” raising concerns about stormwater infiltration impacts to groundwater, the need and support for monitoring at points of municipal stormwater control measures, and that PFAS may be found in stormwater infiltrated for disposal to protect surface water quality.
  • Additionally, NGWA’s joint comments with the Ground Water Protection Council to the EPA on October 19, 2020 on the EPA’s “Proposed 2020 Financial Capability Assessment for Clean Water Act Obligations” raised concerns about funding stormwater infiltration projects under the NPDES program impacting groundwater quality and the need for guidance to design stormwater infiltration systems that are protective of groundwater, and for technical and financial support for small water systems.

NGWA has long been an industry leader in providing PFAS research, education, and resources to the public and scientific communities. In 2017, NGWA published Groundwater and PFAS: State of Knowledge and Practice, which was one of the first PFAS guidance documents to be released.

It can be found at, which is a complete resource center about the groundwater contaminant featuring an FAQs document, a top-10 facts sheet, a homeowner checklist, and more.

NGWA’s newest documents on PFAS are two fact sheets. PFAS Risk Communication for Contractors is written by members of NGWA’s PFAS Task Force to aid communication between water well contractors and their clients on the growing risks of PFAS contamination. PFAS and Private Well Owners: What You Need to Know, is written in an accessible and easy-to-understand way and focuses on everything private well owners should know about the impacts of PFAS on their wells.

Click here to read more about the EPA’s new interim strategy.