POTW Influent PFAS Study
The POTW Influent PFAS Study will collect nationwide data on industrial wastewater discharges of per- and polyfluoroalkyl substance (PFAS) into the environment. This information collection will produce a robust, national data set that will enable the EPA to characterize the type and quantity of PFAS in industrial discharges. The EPA will use this wastewater sampling data to identify and prioritize industrial point source categories where additional study or regulations may be warranted to control PFAS discharges.
The information collection request supporting this study also includes provisions for collecting data for the National Sewage Sludge Survey (NSSS). More information on the NSSS can be found here.
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Current Status
The POTW Influent PFAS Study is currently going through the Information Collection Request (ICR) approval process. The second Federal Register Notice was posted on October 10, 2024, and public comments are being accepted until November 12, 2024. See the Federal Register Notice for instructions on submitting comments.
• Federal Register Notice announcing proposed ICR (March 26, 2024)
• Second Federal Register Notice (October 10, 2024)
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ICR Supporting Statement Part A (pdf)
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ICR Supporting Statement Part B (pdf)
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Draft questionnaire (pdf)
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.
For assistance in reading these documents, please contact the EPA staff listed in the Additional Information section.
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, published in January 2023, the EPA plans to conduct the POTW Influent PFAS Study primarily to gather nationwide data on industrial sources of PFAS discharges to the environment. To accomplish this goal, the EPA will require POTWs across the United States to complete a questionnaire and collect wastewater samples to obtain information on PFAS concentrations in industrial effluent, as well as in domestic wastewater or sewage and in POTW influent and effluent.
Study Design
Questionnaire
As part of the POTW Influent PFAS Study, the EPA intends for approximately 400 POTWs (defined by Section 212 of the Clean Water Act as individual wastewater or standalone wastewater treatment plants owned by a state or municipality) to complete a mandatory electronic questionnaire. The EPA is prioritizing POTWs with daily design flow rates greater than or equal to 10 million gallons per day (MGD) and a service population greater than or equal to 50,000 people.
A notification letter will be delivered to the selected POTWs ahead of the questionnaire. This letter will include the following:
• Instructions
• Access information
• An explanation of obligation to submit a complete and timely response
The EPA will also make available a helpline, via email and phone, to support and answer any questions. The questionnaire will contain roughly 20 questions covering the following topics:
• General facility information
• Wastewater influent and industrial sources
• Wastewater management practices
• Sewage sludge and biosolids management
• Monitoring and sampling analysis
All information and data requested in the questionnaire should be readily available. The EPA does not expect POTWs to have to collect any new data or perform any non-routine tests in order to complete the questionnaire. Responses to the questionnaire will be used by the EPA to identify industrial users for sampling and will include opportunities for POTWs to provide input and recommendations for known or suspected PFAS discharges within their sewersheds.
Sampling
The EPA will use the information and data collected in the questionnaire to select 2,000 industrial users to be sampled by 200 to 300 POTWs. Each POTW selected for sampling will be required to collect the following:
• 10 samples on average from different industrial users (IUs) selected by the EPA
• A domestic sample
• POTW influent and effluent samples
• QC samples
The EPA will provide a sampling plan with detailed information on what is required of selected POTWs and how to complete the sampling. As part of sampling, POTWs will be responsible for the following:
• obtaining sampling supplies
• contracting labs for analysis
• collecting samples specified by the EPA
• notifying EPA when samples are submitted for analysis
• reviewing and compiling the sample results in the specified format
In an effort to both improve lab capacity and reduce costs associated with analyzing wastewater samples from 200 to 300 POTWs simultaneously using EPA Methods 1633 and 1621, the EPA will stagger sampling and analysis.
Selected POTWs for sampling and analysis will be broken up into 4 groups, with each group containing a geographical spread of POTWs from across the country. All samples will be grab samples. Samples will be analyzed using EPA Method 1633, which measures 40 PFAS analytes, and EPA Method 1621, which measures adsorbable organic fluorine (AOF).
Voluntary Data Submission Portal
The EPA will develop a data submission portal to allow states, municipal authorities, service agencies, control authorities, POTWs not selected for mandatory sampling, and other stakeholders and interested parties to voluntarily submit existing data characterizing PFAS and AOF in discharges from industrial facilities, domestic wastewater or sewage, and POTW influent and effluent. The EPA will accept PFAS and AOF sampling results that meet these acceptance criteria, regardless of when the samples were collected and the laboratory method used to analyze the samples.
The EPA requires all relevant PFAS and AOF monitoring data to be submitted in a standardized workbook format. The EPA will use relevant data submitted through this data submission portal to augment data collected through the mandatory sampling program as part of the POTW Influent PFAS Study. The EPA anticipates that this approach will increase the volume of PFAS monitoring data collected and reviewed for the study.
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 ([email protected]) or 202-564-5088.
Media inquiries regarding the study should be directed to the EPA’s Press Office ([email protected]).