The EPA recently solicited feedback from stakeholders on draft language outlining the publicly owned treatment works (POTW) influent per- and polyfluoroalkyl substances (PFAS) study, a.k.a. EPA POTW Influent Study.

Initially announced in its Effluent Guidelines Program Plan 15, this proposed study collects data on industrial discharges of PFAS to POTWs across the country. The EPA has since emphasized that the details and the list of POTWs included in the study are still being revised. While the language is not finalized, the draft does offer a view of the potential details of the study for possible compliance clues.

Who

The original draft announcement provided a list of 400 POTWs for potential sampling. Currently, EPA is working with National Association of Clean Water Agencies (NACWA) and others to revise the study based on initial feedback.

What

Selected POTWs may be required to collect samples of influent, effluent, and biosolids to be analyzed for PFAS, as well as other parameters of interest. The provided sampling plan will include specific instructions for sampling procedures, methods, location parameters, etc. It is important to note that this sampling may be combined with the current sampling plans driven by state or federal regulations or permits (e.g., NPDES) to avoid duplication of efforts.

When

At this point, timing is unknown. The EPA is currently reviewing comments and feedback on the draft language, after which it will seek approval from the Office of Management and Budget. The EPA is hopeful that sampling will occur in mid to late 2024 through early 2025.

Why

EPA’s intent for the potential study is to:

• Develop a collection of wastewater samples from industrial users, grouped by industrial category
• Determine predominant industrial dischargers of PFAS within the United States
• Characterize PFAS discharged from industrial users and domestic sources
• Potentially establish technology-based controls, effluent limits, or other controls for PFAS by industrial category

Points to consider now

While we await the final study guidance from the EPA, there are some considerations POTWs can explore now. Note: While not all facilities will be required to sample under this plan, evolving regulations at local, state, and federal levels may trigger sampling at some point in the future.

Sampling

When it comes to changes to or addition of PFAS sampling requirements, there are several actions you can take to help your facilities to be responsive, efficient, and financially responsible:

• Not all laboratories are approved to provide the PFAS analytical services outlined in the EPA’s sampling plan. Discussing this with your lab contacts and/or seeking out a certified lab early can help make future sampling collection efforts go smoother, if required.
• PFAS sampling requirements can increase sampling costs and may demand additional resources long term, affecting budgets and staff planning. Requesting laboratory quotes for the anticipated analytical methods and estimating staffing requirements for potential sampling will help better align your planning and budgets in advance.
• The analytical methods recommended are Draft Methods 1621 and 1633. Draft Method 1621 is a screening method that estimates the total concentration of organoflourines in aqueous samples. Draft Method 1633 is a targeted method that measures the concentrations of 40 PFAS compounds.
• Proactively developing Standard Operating Procedures (SOPs) for sampling at your facility will help avoid cross contamination and enhance data accuracy and precision.

Stakeholder communication

The protection of local water resources is an important topic for most communities, especially when “forever chemicals” are involved. Clear, honest, and timely communications can be a key factor at gaining stakeholder buy-in on PFAS management and mitigation plans. Being prepared with a strategic plan for communicating PFAS data, potential associated risks, and mitigation alternatives can help educate community members and address their concerns early.

Industrial users

This proposed EPA study is expected to drive exploration “upstream” to the significant industrial users (SIUs) and others who discharge to the POTWs. Distinguishing among industrial, commercial, and residential discharges will inform how best to approach mitigation.

Support

The emergence of PFAS contaminants is very new to most, and the evolving regulatory requirements associated with them can be difficult to navigate without experienced support. With subject matter experts, insights from key relationships with regulatory agencies, and leadership of cutting-edge research, BC’s PFAS team can help you adapt to what’s emerging and properly prepare you for regulatory and technical requirements.