NACWA Files Comments on ELG Plan, Encourages PFAS Focus

(December 4, 2019) - In November 25 comments on EPA’s Preliminary Effluent Guidelines Program Plan 14, NACWA asked EPA to broaden its study of industries that may discharge PFAS. 

The Preliminary Plan provides the results of EPA’s annual review of effluent guidelines and pretreatment standards and updates of ongoing category studies.  EPA is conducting a review of industries to better understand PFAS discharges, and EPA states in the plan that it will conduct a detailed study of the PFAS use, treatment, and discharge by airports, organic chemical manufacturers, paper and paperboard manufacturers, and textiles and carpet manufacturers.  NACWA asked EPA to expand the detailed study to industrial categories such as metal finishing and landfills that may warrant pretreatment standards for PFAS discharges to publicly owned treatment works (POTWs).

NACWA also supported EPA’s ongoing study of nutrient discharges from industries but pointed out that any analysis or decisions related to nutrients must also consider the nonpoint sources that can be the greatest source of nutrients in many watersheds.  The nutrient reduction efforts of POTWs must be understood and appreciated compared to the nutrient contributions from sources outside POTW control. 

NACWA encouraged EPA to revise the effluent guidelines and pretreatment standards for the Electrical and Electronic Components (E&EC) category.  These guidelines have not been updated since they were issued in 1983, and the industry has changed dramatically since that time.  An update would benefit POTWs with E&EC facilities in their service areas.  NACWA members that have information about these types of facilities are encouraged to contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.