The National Pollutant Discharge Elimination System (NPDES) was added as an amendment to the Clean Water Act in 1972. Although PFAS testing is not yet mandated nationwide through the NPDES program, the U.S. EPA released guidance to the states in late 2022, recommending that state administrators consider adding PFAS in wastewater (and later stormwater and biosolids) to their NPDES permits.
Based on recent feedback from clients and the industry, it’s my sense that we’re at a tipping point. If your business is in a targeted industry, especially airports, landfills, metal finishing, or Organic Chemicals Plastics and Synthetic Fibers (OCPSF), you should be prepared for PFAS monitoring, reporting, and in some cases, remediation action plans to be added to your NPDES permit requirements.
In early August, I teamed up with Lucas Barroso-Giachetti, Senior Environmental Engineer and Regional PFAS Technical Lead with Terracon, to discuss PFAS requirements in NPDES permits and how businesses and organizations can prepare to meet them.
Watch: PFAS Strategies for Industrial and Logistics Operators
This webinar included such a wide array of information that it will take me at least a couple of posts to hit the important points. In today’s post, we start by examining a couple of real-world NPDES permits and discussing their implications for industrial and commercial clients.
PFAS NPDES Permits Vary Greatly
Once ELGs are established, they are enforced through NPDES permitting. Until then, state administrators have a wide degree of latitude regarding how permits are written and whether to include PFAS. To illustrate just how different permit requirements can be, Lucas shared examples from two of his clients in the webinar.
Alabama Landfill - A landfill had previously accepted PFAS-impacted sludge from a large manufacturer, so the state added indirect discharge monitoring to their NPDES permit. This particular permit specifies EPA 1633 be used to analyze the discharge and lists the targeted PFAS that must be measured. The results are to be recorded in parts per trillion (ppt), but the permit does not specify required detection limits. With performance-based methods like EPA 1633, detection limits can vary by laboratory, so it's important to ensure your lab can meet any specific data quality objectives.
If you aren’t familiar with the term “performance-based method,” it simply means laboratories are allowed to modify the method to meet enhanced quality objectives. For example, they can expand the list of compounds beyond the 40 targeted compounds detectable by EPA 1633. They can also adjust the methodology to meet specific reporting limit requirements while maintaining data quality. I will cover more technical details about the various available test methods in my next post.
Lastly, this permit also requires the landfill to create a PFAS reduction plan that includes semi-annual reporting and trend analysis. While this is a relatively new feature of PFAS permitting, our PFAS Treatability Studies team is seeing more requests for pilot projects based on requirements like these – or the anticipation of them in some cases.
Illinois Commercial Facility - This permit added PFAS to the facility’s normal quarterly testing requirements for stormwater. EPA 1633 is the required method, but unlike the Alabama example, the permit specifies detection limits for regulated PFAS at 2 ppt. Once again, the permit requires a plan to address PFAS, which they refer to as a PFAS minimization program.
Stormwater produces some unique challenges as the source of the PFAS can be difficult to pinpoint. Since depositions of airborne PFAS can migrate into the stormwater retention system during precipitation events, Terracon advises clients to consider whether their facility or property is in an urban setting likely to have a background level of PFAS. To establish a baseline, Lucas suggested checking with the appropriate state agency to see if local rainfall is tested for PFAS. You can also test rainfall collected onsite; however, the results are likely to include any PFAS released by your facility through air emissions so the results are less useful as a baseline measurement.
As discussed in the webinar, testing sediment collected from your stormwater containment area may also be informative as it can leach PFAS picked up from other areas into your stormwater discharge. PFAS has become a required component of many Environmental Site Assessments, and Terracon advises clients to do baseline tests of these sediments as part of their due diligence before assuming responsibility for new properties.
Next Up: Your PFAS Analytical Toolbox
Analyzing a variety of matrices to fulfill (or get ahead of) compliance requirements will require a robust PFAS test method tool kit. In my next post, I’ll go into available test methods, pointing out some of the advantages and disadvantages of each method. I’ll also share an important tip for minimizing cost. In the meantime, I encourage you to watch the webinar. If you have questions that we didn’t get to during the Q&A, feel free to reach out to us. We’re also happy to provide a quote for PFAS testing services for NPDES compliance as well as discuss your PFAS remediation strategies and how a PFAS Treatability Study can help you identify the most effective and cost-efficient approach.