May 26, 2021

Industry Associations Provide Feedback for Clean Water Act Effluent Limitations Guidelines and Standards

The feedbacks relates to the effluent limitations guidelines, pretreatment standards and new source performance standards applicable to the Organic Chemicals, Plastics and Synthetic Fibers point source category to address PFAS discharges.


The Association of Clean Water Administrators (ACWA), the Association of State Drinking Water Administrators (ASDWA), the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), and the Environmental Council of the States (ECOS) provided comments about the Clean Water Act Effluent Limitations Guidelines and Standards: Organic Chemicals, Plastics and Synthetic Fibers Point Source Category Advanced Notice of Proposed Rulemaking. 

According to EPA, the agency has identified several industries with facilities that are likely to be discharging PFAS in their wastewater, including OCPSF manufacturers and formulators.

The agency is soliciting additional information and data regarding PFAS manufacturers and formulators including wastewater characteristics and treatability, according to EPA. The data will inform potential next steps, which could include developing new or revised ELGs for these categories of dischargers.

"In carrying out these programs, states must ultimately address national regulatory changes and data collection efforts that can affect their ability to manage surface water, drinking water, and cross-media pollutants,” stated Samantha Lewis, Office of Water, Engineering and Analysis Division in a joint press release from the industry associations regarding these guidelines, as well as the effluent limitations guidelines (ELGs) and PFAS standards.

According to the press release, there are seven specific recommendations compiled by the associations for the EPA regarding the future rule: 

  • Collaborate on PFAS data collection and sharing;
  • Engage with states on PFAS;
  • Integrate data collection opportunities into the suite of EPA activities into the future, with specific focus on discharge data and treatment options;
  • Develop PFAS discharge prioritization guidance for states;
  • Evaluate other ELG categories that may apply to industries in which PFAS discharges have been quantified or may exist;
  • Consider developing PFAS standard(s) for facilities using PFAS in products or processes;
  • And use existing data in addition to generating new PFAS data.

According to the joint press release, the PFAS standards are an opportunity to enable states, EPA, and their stakeholders to better control and prevent PFAS pollution upstream. The aim is to consider the impacts of PFAS from manufacturing through processing, distribution, and disposal. 

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