In comments on an Advance Notice of Proposed Rulemaking (ANPRM), NACWA supported EPA’s step towards developing effluent limitation guidelines (ELGs) and pretreatment standards for discharges of per- and polyfluoroalkyl substances (PFAS) from PFAS formulators and manufacturers.  EPA published the ANPRM, which applies to the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) point source category, on March 17.

NACWA supports ELGs and pretreatment standards as an effective way of controlling PFAS at its sources.  Since there are currently no cost-effective techniques available to treat PFAS in the volumes of wastewater managed by clean water utilities, controlling PFAS at the source is the most viable option.  NACWA asked EPA to continue its study of other PFAS-discharging industrial categories, such as airports, paper and paperboard manufacturers, and textile and carpet manufacturers.  NACWA also asked EPA to study categories that typically discharge wastewater containing PFAS to POTWs, such as metal finishers and landfills. 

NACWA requested that any ELGs and pretreatment standards developed for PFAS be as flexible as possible, to account for the new information and treatment technologies that are likely to emerge as research on PFAS continues.  In addition, NACWA recommended that POTWs not be made responsible for enforcing limits on PFAS that would be nearly impossible to enforce, such as a “zero discharge” limitation. 

NACWA will monitor EPA’s actions related to pretreatment standards for PFAS.  Members with questions about the ANPRM should contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.