Study of PFAS Influent to POTWs
The EPA will collect nationwide data on industrial discharges of per- and polyfluoralkyl substances (PFAS) to publicly owned treatment works A municipal or public service district sewage treatment system. (POTWs). The POTW Influent PFAS Study will include analysis of indirect discharges from categories recently reviewed by the agency and categories identified as discharging PFAS, but for which insufficient monitoring data exist.
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Background
The EPA’s PFAS Strategic Roadmap identifies the unique challenges posed by PFAS contamination and states its approach includes a "deeper focus to preventing PFAS from entering the environment in the first place—a foundational step to reducing the exposure and potential risks of future PFAS contamination."
As announced in the EPA's Effluent Guidelines Program Plan 15 (January 2023), the EPA is conducting a POTW Influent PFAS Study to collect and analyze nationwide data on industrial discharges of PFAS to POTWs, as well as PFAS in POTW influent, effluent, and sewage sludge. The EPA will require, through an OMB-approved Information Collection Request (ICR), a subset of large POTWs across the United States to complete a questionnaire and collect and analyze wastewater and sewage sludge samples.
The information collection activities will produce a robust data set that will enable the EPA to characterize the type and quantity of PFAS in wastewater discharges from industrial users to POTWs (including industrial categories that the EPA has determined historically or currently use PFAS, but for which insufficient PFAS monitoring data are available) as well as POTW influent, effluent, and sewage sludge. The wastewater sampling data will primarily be used to identify and prioritize industrial point source categories where additional study or regulations may be warranted to control PFAS discharges. The sewage sludge sampling will fulfill the EPA’s data needs for the upcoming National Sewage Sludge Survey (NSSS) by establishing a current national data set of sewage sludge characteristics which the EPA will subsequently use to inform upcoming risk assessments and the need for future regulations and guidance pertaining to the management of sewage sludge.
This collection effort is necessary because there are only very limited publicly accessible data on PFAS discharges from industrial categories to POTWs, the relative PFAS contributions from residential, commercial, and industrial sources to POTWs, and the fate and transport of PFAS in POTW influent and sewage sludge. This project supports the Agency’s PFAS Strategic Roadmap commitments to address PFAS through investment in scientific research to fill gaps in understanding of PFAS and to prevent PFAS from entering the environment.
The EPA’s Office of Water has consulted with individuals in the POTW industry, its trade associations, and consultants to solicit their input on the need and use of a questionnaire and sampling program. From August 2023 through January 2024, the EPA discussed the design and objectives of the POTW Influent PFAS Study with representatives from the National Association of Clean Water Agencies (NACWA), Association of Clean Water Administrators (ACWA), the Environmental Council of the States (ECOS), and states and EPA regional offices participating in the agency's monthly national pretreatment meetings. The EPA plans to continue meeting and soliciting comments from these stakeholders throughout the development and administration of the questionnaire and sampling program.
Study Design
As part of the POTW Influent PFAS Study, the EPA estimates that approximately 400 POTWs with the highest daily flow rates in the U.S. will complete a mandatory electronic questionnaire. The objectives of the questionnaire will be to gather POTW-specific information and data on industrial users discharging to the POTW, known or suspected sources of PFAS discharges to the POTW, and wastewater and sewage sludge management practices of the POTW.
The EPA plans to use the information and data collected in the questionnaire to select a subset of 200 to 300 POTWs to participate in a two-phase sampling program.
- Phase 1 will require each selected POTW to collect and analyze one-time grab samples of industrial user effluent, domestic wastewater influent, POTW influent, and POTW effluent for forty specific PFAS and adsorbable organic fluorine (AOF). For each POTW selected, the EPA intends to specify no more than ten industrial users for which the POTW must collect and analyze effluent samples. The total number of industrial users sampled as part of the sampling program is not expected to exceed 2,000 facilities.
- Phase 2 will require selected POTWs to collect and analyze one-time grab samples of sewage sludge for forty specific PFAS and ancillary parameters.
The EPA will also develop a data submission portal which will allow states, municipal authorities, and POTWs (including those not selected to complete the questionnaire or sampling program) to voluntarily submit existing data characterizing PFAS in industrial user effluent, domestic wastewater, and POTW influent, effluent, and sewage sludge/biosolids. The EPA anticipates that this approach will increase the volume of PFAS monitoring data collected and reviewed for the study.
Draft Questionnaire
The EPA is soliciting public comments on this proposed collection and such comments are due by May 28, 2024. See the Federal Register Notice for instructions on submitting comments.
- Federal Register Notice announcing proposed ICR (March 26, 2024)
- Information Collection Request Supporting Statement Part A (pdf)
- Information Collection Request Supporting Statement Part B (pdf)
- Draft Questionnaire (pdf)
For assistance in accessing the draft questionnaire, please contact Sean Dempsey (dempsey.sean@epa.gov) or 202-564-5088.
All supporting materials for the rulemaking and proposed ICR can be found at the EPA's docket at regulations.gov. The Docket Number is EPA-HQ-OW-2023-0580.
Additional Information
The EPA welcomes additional data and participation from states and POTWs who have collected their own data or are planning their own PFAS monitoring studies. If you have any information and data to share with the EPA or require additional information regarding the POTW Influent PFAS Study, please contact Sean Dempsey (dempsey.sean@epa.gov) or 202-564-5088.
Media inquiries regarding the study should be directed to the EPA’s Press Office (press@epa.gov).