January 4, 2021
Recommendations include phased-in monitoring requirements, information sharing & best management practices
On November 30, 2020, the U.S. Environmental Protection Agency (EPA) Office of Water released recommendations for managing per- and polyfluoroalkyl substances (PFAS) in EPA-issued National Pollutant Discharge Elimination System (NPDES) permits. EPA is the permitting authority for Massachusetts, New Hampshire, New Mexico, the District of Columbia, U.S. territories, and certain federal facilities. As part of EPA's PFAS Action Plan, a workgroup comprising the Office of Water and regional representatives developed an interim strategy that includes phased-in monitoring of PFAS in point source wastewater discharges and stormwater discharges, as well as the development of an information-sharing platform on permitting practices.
In accordance with the Clean Water Act (CWA) Section 402 NPDES, the workgroup recommends incorporating EPA-issued permit requirements for monitoring PFAS at facilities where the compounds are expected to be present in point source wastewater discharges. These facilities are identified by the permit writer based on available information and data from similar facilities or known raw materials, products, or byproducts used or generated at the facility.
Currently, EPA does not have a validated CWA analytical method for PFAS but is working to develop a test method for 40 PFAS compounds in wastewater and other media, which is expected to be finalized in 2021. Therefore, the workgroup recommends the monitoring requirement be triggered after the validated method is available to the public, with a similar phased-in approach for monitoring PFAS in municipal separate storm sewer system (MS4) and industrial stormwater permits when the compounds are expected to be present. The recommendations also include the incorporation of best management practices and stormwater controls to reduce PFAS discharges.
How Exponent Can Help
Exponent's expert consultants in regulatory compliance consider both state and federal regulations when developing strategic solutions for our clients' needs. Our multi-disciplinary team of environmental scientists and chemical engineers can help evaluate permitting requirements, choose qualified laboratories for monitoring analysis, and validate PFAS data to ensure usability and compliance. Our experts can also assist with upstream mitigation assessments of PFAS in wastewater through source identification and fingerprinting to help clients manage their regulatory and environmental liabilities.