EPA Releases Supplemental Guidance For PFAS Monitoring
On December 5, the U.S. Environmental Protection Agency (USEPA) released supplemental guidance to states for how to use the National Pollutant Discharge Elimination System (NPDES) permit to address PFAS pollution in wastewater. The purpose of this guidance is to provide information to permit writers on how to use existing authorities to reduce PFAS discharges in NPDES permits while the Agency finalizes its Effluent Limitation Guidelines for PFAS.

For publicly owned treatment works (POTWs), the guidance using draft method 1633 for monitoring activities on a quarterly basis. Additionally, permits should include requirements that POTWs identify and locate all possible industrial users that may be subject to PFAS pretreatment program, along with the volume of pollutants contributed to POTWs by the industrial users.

The guidance also recommends that where appropriate, states begin working with POTWs to reduce PFAS in biosolids and cites the following steps: use draft method 1633 to analyze presence of PFAS in biosolids; indicate the presence of PFAS in biosolids from industrial sources; validate PFAS reductions with regular monitoring of biosolids.

Please reach out to Sarah Sapirstein with questions or comments about the newest direction from USEPA as the Agency continues to use the PFAS Strategic Roadmap (Roadmap) to guide its regulatory actions on PFAS, which had identified using NPDES permits to reduce industrial PFAS discharges at the source and recommended increased monitoring to obtain more information on the sources of PFAS pollution.