ECOS, ACWA, ASDWA, and ASTSWMO submitted these joint comments on the Clean Water Act Effluent Limitations Guidelines and Standards: Organic Chemicals, Plastics and Synthetic Fibers Point Source Category Advanced Noticed of Proposed Rulemaking and ensuing Effluent Limitations Guidelines, Pretreatment Standards, and New Source Performance Standards applicable to PFAS. The associations outline considerations for EPA, including these recommendations:
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
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