EPA Memo: Interim Strategy for PFAS in Federally Issued NPDES Permits, Nov. 2020
In November 2020, this EPA Memo provides recommendations for an interim strategy to address PFAS monitoring in NPDES permits – both for wastewater and stormwater discharges. Jeff Marshall recommends reading it and highlights excerpts. Jeff notes it will be interesting to see how soon state permit writers begin adding PFAS monitoring requirements to landfill NPDES permits.
The workgroup recommends that EPA NPDES permit writers consider incorporating permit requirements for monitoring PFAS at facilities where PFAS are expected to be present in point source wastewater discharges.
The workgroup recommends considering pollutant control measures in municipal separate storm sewer (MS4) and industrial stormwater permits when PFAS are expected to be present in stormwater discharges. In addition, the workgroup recommends a phased approach to incorporating monitoring in these permits, as described above, when deemed appropriate by the permit writer.
On page 4, the EPA presents a proposed schedule for implementing several aspects of the program during the first half of 2021.
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