The U.S. Environmental Protection Agency released on December 6 a memorandum to states that provides direction on how to use the nation’s clean water permitting program to protect against per- and polyfluoroalkyl substances (PFAS).
The guidance released, which outlines how states can monitor for PFAS discharges and take steps to reduce them where they are detected, is part of the agency’s holistic approach to addressing these harmful forever chemicals under EPA’s PFAS Strategic Roadmap.
This action is a critical step in the EPA’s efforts to restrict PFAS at their source, which will reduce the levels of PFAS entering wastewater and stormwater systems and ultimately lower people’s exposure to PFAS through swimming, fishing, drinking, and other pathways.
The memorandum, Addressing PFAS Discharges in National Pollutant Discharge Elimination System (NPDES) Permits and Through the Pretreatment Program and Monitoring Programs, will align wastewater and stormwater NPDES permits and pretreatment program implementation activities with the goals in EPA’s PFAS Strategic Roadmap. The memo recommends that states use the most current sampling and analysis methods in their NPDES programs to identify known or suspected sources of PFAS and to take actions using their pretreatment and permitting authorities, such as imposing technology-based limits on sources of PFAS discharges.
The memo will also help the agency obtain comprehensive information through monitoring the sources and quantities of PFAS discharges, informing other EPA efforts to address PFAS.
Several states have already demonstrated the benefits of leveraging their state-administered NPDES permit programs to identify and reduce sources of PFAS before these forever chemicals enter treatment facilities and surface waters.
Michigan, for example, is partnering with municipal wastewater treatment facilities to develop monitoring approaches to help identify upstream sources of PFAS. The state has been able to leverage monitoring information to work with industries, such as electroplating companies, to substantially reduce PFAS discharges. North Carolina has also successfully leveraged its NPDES program to develop facility-specific, technology-based effluent limits for known industrial dischargers of PFAS. This memo urges states to replicate these approaches and use others noted in the memo to identify and reduce PFAS discharges.
This memo builds upon the agency’s April 2022 memo to EPA regions by expanding the audience to states and including new recommendations related to biosolids, permit limits, and coordination across relevant state agencies. The memo provides recommendations to NPDES permit writers and pretreatment coordinators, rooted in the successful use of these tools in several states, on monitoring provisions and analytical methods and the use of pollution prevention and best management practices. These provisions will help reduce PFAS pollution in surface waters as the agency also works to promulgate effluent guidelines, finalize multilaboratory validated analytical methods, and publish water quality criteria that address PFAS.
Click here to learn more.
NGWA has long been an industry leader in providing PFAS research, education, and resources to the public and scientific communities. Learn more by visiting NGWA.org/PFAS, which is a complete resource center about the groundwater contaminants featuring a recently updated top-10 facts sheet, a position paper, and more.
Also found there is Groundwater and PFAS: State of Knowledge and Practice, which NGWA published in 2017 and is one of the first PFAS guidance documents to be released. The Association hosted its second conference earlier this year in Westerville, Ohio, focused entirely on PFAS science and remediation.