(February 6, 2020) – In another step to address PFAS, the US Environmental Protection Agency (EPA) accepted comments on an advanced notice of proposed rulemaking (ANPRM) asking whether to list certain PFAS compounds to the Toxic Release Inventory (TRI). EPA also sought public input on what the reportable quantities or thresholds should be for reporting if these chemicals were to be listed on the TRI.
NACWA submitted comments on February 3 supporting EPA’s efforts to list certain chemicals on the TRI. Adding facilities that manufacture or use these chemicals will aid public clean water utilities in better understanding the upstream sources and quantities of PFAS entering their treatment systems.
As public interest in PFAS continues, municipal clean water utilities – which are not manufacturers or sources of PFAS, but passive receivers that generally must accept whatever has been discharged into their collection systems – are beginning to evaluate the makeup of industrial users in their communities. Identifying the actual sources and quantities, which the TRI will assist with, will help POTWs identify additional or unknown facilities that are contributing PFAS compounds to wastewater treatment plants.
EPA’s ANPRM mirrors the Agency’s PFAS Action Plan and underscores the effort needed to gather input on how to best approach the inherent complexities of PFAS, including toxicological uncertainties and appropriate reportable thresholds.
If members have questions, please contact Emily Remmel, NACWA’s Director of Regulatory Affairs.