ASDWA, ACWA, ECOS, ASTSWMO Submit Joint Letter to EPA on PFAS Effluent Limitations Guidelines

On May 17, ASDWA, the Association of Clean Water Administrators (ACWA), the Environmental Council of the States (ECOS), and the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) submitted a joint letter of comment to EPA on the “Clean Water Act Effluent Limitations Guidelines (ELGs) and Standards: Organic Chemicals, Plastics and Synthetic Fibers Point Source Category Advanced Noticed of Proposed Rulemaking.” Together, our organizations represent the state, interstate, and territorial environmental and public health program managers and commissioners who implement the Clean Water Act (CWA), Safe Drinking Water Act (SDWA), and other national and state environmental statutes, that have the potential to be impacted by these ELGs, Pretreatment Standards, and New Source Performance Standards for PFAS.

The joint letter highlights the need for this future rule to help control and prevent PFAS pollution as part of holistic approach, that also addresses the difficulty in generating relevant PFAS data due to the lack of analytical methods and expense for monitoring surface waters and other exposure pathways. The letter provides seven specific recommendations for EPA to:

  1. Collaborate on PFAS Data Collection and Sharing
  2. Engage with States on PFAS Generally
  3. Integrate Data Collection Opportunities into the Suite of EPA Activities into the Future, with Specific Focus on Discharge Data and Treatment Options
  4. Develop PFAS Discharge Prioritization Guidance for States
  5. Evaluate Other ELG Categories that May Apply to Industries in which PFAS Discharges Have Been Quantified or May Exist
  6. Consider Developing PFAS Standard(s) for Facilities Using PFAS in Products or Processes, Potentially Beyond the Scope Identified in this Future Rule
  7. Use Existing Data in Addition to Generating New PFAS Data

For more information, read the letter here.