Posted by Stacy Silva on Wednesday, March 12, 2025
If you have received a new or renewed National Pollutant Discharge Elimination System (NPDES) permit recently, you may have noticed a few new requirements regarding PFAS. Not to fear, we break down what this means to Publicly-Owned Treatment Works (POTWs) and their contributing industries below!
The U.S. Environmental Protection Agency (EPA) announced that new and reissued NPDES permits for POTWs with approved Industrial Pretreatment Programs (IPPs) in PA and DE of EPA Region 3 will begin incorporating quarterly PFAS sampling requirements that, at a minimum, includes quarterly influent, effluent, and sludge analysis for the 40 PFAS parameters detectable by EPA Method 1633.
New PFAS Sampling for POTW NPDES Permits:
| Parameter: 40 PFAS Analytes | Maximum Daily | Monitoring Frequency | Monitoring Sample Type |
| Influent (ng/L) | Report | 1 per quarter for 12 quarters | Grab |
| Effluent (ng/L) | Report | 1 per quarter for 12 quarters | Grab |
| Sludge (ng/g) | Report | 1 per quarter for 12 quarters | Grab |
In addition to the table above, under the POTW’s NPDES permit, POTWs with approved IPPs shall require annual sampling (utilizing EPA Method 1633) for industrial user discharges suspected of containing PFAS, including the following types of industrial users (IUs):
- Airports;
- Centralized waste treatment;
- Electroplating;
- Electric and electronic components;
- Fire training;
- Landfills;
- Leather tanning and finishing;
- Metal finishing;
- Organic chemicals;
- Plastics and synthetic fibers (OCPSF);
- Paint formulating;
- Plastics modeling and forming;
- Pulp, paper and paperboard;
- Textile mills;
- Sites known or suspected of PFAS contamination; and
- Any other sources expected or suspected of PFAS discharges.
|
Monitoring data for both POTW quarterly sampling and IU annual sampling shall be summarized and submitted as part of the IPP Annual Report. Influent, effluent, and sludge sampling at the POTW may be discontinued after 12 consecutive quarterly sampling events have been conducted, dependent on test results. The IU discharge monitoring may be discontinued after five (5) annual sampling events, dependent on test results.
The IPP Annual Report will also require an updated listing of IUs in industry categories expected or suspected of PFAS discharges, as well as a summary of actions taken by IUs to reduce, substitute, or eliminate PFAS, such as best management practices (BMPs) implemented by IUs.
POTWs without an approved pretreatment program will be required to develop a list of IUs in the industrial categories listed above and submit the list to EPA within six (6) months of the permit effective date.
6 Actions to Get Started
Download the checklist here (pdf)
The following steps are provided to help ensure that you and your IUs are prepared for the new PFAs requirements.
1. Estimate new PFAS sampling costs and include in annual budgeting (influent, effluent, and sludge).
PFAS sampling can significantly increase a POTW’s overall annual sampling costs. Gather cost estimates from contract laboratories, including any potential extra expenses for sample collection, for more accurate annual budgeting.
2.Determine who will conduct PFAS sampling (contract laboratory or POTW staff).
The risk for nonintentional cross-contamination is high in PFAS sampling. Clothing, lotions, and make-up are just a few potential sources of cross-contamination! Proper procedures and protocols are a must. Although laboratory staff are experienced in the dos and don’ts for PFAS sampling, in many cases, this comes as an extra cost if performed by laboratory staff.
3. Contact laboratories for sample scheduling ASAP!
Don’t delay – schedule today! With limited PFAS-certified laboratories, it is important to schedule your sampling needs as quickly as possible.
4. Prepare PFAS sample result summaries for IPP annual reporting.
Get a jump start on your IPP annual reporting and begin gathering and summarizing your PFAS sample result data as it is received.
5. Contact IUs to provide a heads up on required PFAS sampling at discharge points, if the IU is within EPA-identified categories of potential PFAS sources.
Contact your IUs to provide information about the new PFAS sampling requirements and discuss BMPs for reducing potential PFAS use in IU processes, if the IU is within one of the EPA-identified categories of potential PFAS sources (see list above).
6. Perform a new IU survey to identify any expected or suspected PFAS sources within your collection system.
Even if your POTW has an established IPP program with known IUs, conducting a new IU survey may be worthwhile in identifying any expected or suspected PFAS sources within your collection system.
Need help? Have questions? My colleagues and I are always eager to help! Also, you can read more of our PFAS Blogs here.
Categories: Municipal Infrastructure
Tagged: Wastewater | Municipal Engineering | Environmental | Health & Safety | PFAS