Last month, EPA made three PFAS/Clean Water Act-related announcements.

First, EPA issued proposed draft Clean Water Act aquatic life criteria for PFOA and PFOS. The proposed draft includes the most up-to-date scientific knowledge regarding the effects of PFOA and PFOS on freshwater organisms, quantifies the toxicity of each chemical to aquatic life, and proposes criteria to protect aquatic life from acute and chronic effects from each chemical. The draft criteria will be open for public comment for thirty days following the publication of these proposed drafts in the Federal Register, which should occur imminently.

Second, EPA issued a memorandum outlining its plan to restrict PFAS discharges into water bodies under the Clean Water Act’s National Pollutant Discharge Elimination System (NPDES). EPA plans to require PFAS monitoring, best management practices such as product substitution, and public notice expectations in connection with federally-issued permits. EPA will also use the NPDES program to obtain comprehensive information on sources and quantities of PFAS discharges to help guide future actions under its Effluent Limitation Guidelines.

In effect, this means that manufacturers in the industries targeted—organic chemicals, plastics & synthetic fiber users and manufacturers; metal finishing; electroplating; electric and electronic component makers; landfills; pulp and paper manufacturers; leather producers; plastics molders; textile mills; paint manufacturers; and airports—will need to implement new best management practices for handling PFAS discharges into water, as well as increased monitoring and reporting of such discharges. EPA will also continue to increase the amount of PFAS data

Third, EPA’s Office of Water put forward a new draft method to measure Adsorbable Organic Fluorine in water samples using combustion ion chromatography (draft EPA method 1621). It detects organofluorines (molecules with a carbone-florine bond), which can be found in thousands of known PFAS compounds as well as non-PFAS chemicals such as pesticides. For now, this has been designated as a screening method given that it has different levels of accuracy for some organofluorines versus others as well as the fact that there are some interferences including solvents, reagents, glassware, or plasticware.

For now, the draft method has gone through single-laboratory validation, with multi-laboratory validation planned for this summer. EPA’s Office of Water is encouraging review, use, and comment on the method as it works towards finalizing.