NACWA provided comments today to EPA on its Preliminary Effluent Guidelines Program Plan 15, which announced rulemakings for several industrial categories to control PFAS and nutrient discharges.  The Plan is published every two years to outline EPA’s planned studies and rulemakings related to effluent limitation guidelines (ELGs) and pretreatment standards for industrial dischargers.  The Plan, an FAQ, and other documents are available on EPA’s website. 

In its comments, NACWA supported the rulemakings EPA is initiating to control discharges of PFAS from the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) and Metal Finishing categories as an effective way of controlling PFAS at its sources.  NACWA requested that 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 publicly owned treatment works (POTWs) not be made responsible for enforcing limits on PFAS that would be nearly impossible to enforce, such as a “zero-discharge” limitation.  NACWA also supported EPA’s ongoing Multi-Industry PFAS Study and the detailed studies announced in the Plan for PFAS discharges from landfills and from textile and carpet manufacturers. 

EPA also announced in Plan 15 that it would begin a rulemaking to address nutrient discharges for the Meat and Poultry Products Category, based on the results of its detailed study of the industry.  Since utilities are under increasing pressure to reduce nutrient discharges, NACWA supports controlling nutrient sources.  However, the Association noted that EPA must understand how controlling nutrient discharges from industries compares to the nutrient contributions from nonpoint sources, which can be the greatest nutrient sources in many watersheds. 

NACWA will continue to communicate with EPA as the Agency develops ELGs and pretreatment standards for PFAS and nutrients.  NACWA members with questions or input on these rulemakings should contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.