New EPA memo provides direction under NPDES permitting program to restrict PFAS at their source the U.S. Environmental Protection Agency (EPA) released a memorandum to states that provides direction on how to use the nation’s bedrock clean water permitting program to protect against per- and polyfluoroalkyl substances (PFAS). The guidance released today, which outlines how states can monitor for PFAS discharges and take steps to reduce them where they are detected, is part of the Agency’s holistic approach to addressing these harmful forever chemicals under EPA’s PFAS Strategic Roadmap.

This action is a critical step in EPA’s efforts to restrict PFAS at their source, which will reduce the levels of PFAS entering wastewater and stormwater systems and ultimately lower people’s exposure to PFAS through swimming, fishing, drinking and other pathways.

“EPA is following through on its commitment to empowering states and communities across the nation to address known or suspected discharges of PFAS,” said EPA Assistant Administrator for Water Radhika Fox. “Today’s action builds upon successful and innovative efforts already used by several states to safeguard communities by using our Clean Water Act permitting program to identify and reduce sources of PFAS pollution before they enter our waters.”

The memorandum, Addressing PFAS Discharges in National Pollutant Discharge Elimination System (NPDES) Permits and Through the Pretreatment Program and Monitoring Programs, will align wastewater and stormwater NPDES permits and pretreatment program implementation activities with the goals in EPA’s PFAS Strategic Roadmap. The memo recommends that states use the most current sampling and analysis methods in their NPDES programs to identify known or suspected sources of PFAS and to take actions using their pretreatment and permitting authorities, such as imposing technology-based limits on sources of PFAS discharges. The memo will also help the Agency obtain comprehensive information by monitoring on the sources and quantities of PFAS discharges, informing other EPA efforts to address PFAS.

Several states have already demonstrated the benefits of leveraging their state administered NPDES permit programs to identify and reduce sources of PFAS before these forever chemicals enter treatment facilities and surface waters. Michigan, for example, is partnering with municipal wastewater treatment facilities to develop monitoring approaches to help identify upstream sources of PFAS. The state has been able to leverage that monitoring information to work with industries, such as electroplating companies, to substantially reduce PFAS discharges. North Carolina has also successfully leveraged its NPDES program to develop facility-specific, technology-based effluent limits for known industrial dischargers of PFAS. This memo urges states to replicate these approaches and use others noted in the memo to identify and reduce PFAS discharges.

This memo builds upon the agency’s April 2022 memo to EPA Regions by expanding the audience to states and including new recommendations related to biosolids, permit limits, and coordination across relevant state agencies. The memo provides recommendations to NPDES permit writers and pretreatment coordinators, rooted in the successful use of these tools in several states, on monitoring provisions and analytical methods and the use of pollution prevention and best management practices. These provisions will help reduce PFAS pollution in surface waters as the Agency also works to promulgate effluent guidelines, finalize multi-laboratory validated analytical methods and publish water quality criteria that address PFAS compounds.

Background
PFAS are a large group of chemicals that are used in consumer products and industrial processes. In use since the 1940s, PFAS are resistant to heat, oils, stains, g

Weekly Death Report Nov 14 to Nov 20, 2022

GAVEL GAMUT

By Jim Redwine

www.jamesmredwine.com

(Week of 19 December 2022)

HOT WARS AND COLD SEATS

Each morning I look off my apartment balcony at the ships floating on the Black Sea that lies between the countries of Georgia on the southeast and Ukraine to Georgia’s northwest. So far the ships have remained of the merchant variety, but I always look first to make sure. Georgia is a country of four million people with virtually no way to defend itself. The Georgian government that fears Russia on Georgia’s northern border and the citizens of Georgia who fly Ukrainian blue and yellow flags are in constant yang and yin over the war being waged just across the Black Sea. The government worries about poking the Russian bear and the citizens publicly rally and demonstrate in support of the Ukraine population.

Recently Russia has been stirring up its long held relationship with the country of Belarus that lies between Russia’s western border and Ukraine’s northern border. Belarus is in the same military condition as Georgia. Belarus, as led by the politically embattled president Alexander Lukashenko, with its nine million citizens, is even more supine to Russia’s might than Georgia. Therefore, Belarus does not pretend to resist Russian moves to use Belarus as a staging ground for Russia’s military and probable invasion of Ukraine. At the very least, Belarus provides Russia with a vital logistical path for re-supply of its military.

This morning, December 15, 2022, I am gazing at the tankers and grain ships right outside my window and, as we humans often experience, a totally unrelated memory of a simpler time comes to mind. In 1954 my family had a new Ford automobile, the kind with front fenders. Some of you will remember fenders and maybe will have even ridden on them to deliver newspapers as my brother Philip and I used to when we could wheedle Mom into driving us along our paper route. In 1954 the Korea War was over and our generation’s war in Viet Nam had not yet begun. The hero of the Normandy Landing of WWII, Dwight Eisenhower, was president of the United States and America was keeping the Soviet Union on its heels, not with bombs but with the humanitarian Marshall Plan.

In those halcyon days in Pawhuska, Oklahoma the Pawhuska Journal Capital newspaper was owned and operated by Glen Van Dyke and Phil and I had one of the delivery routes. We would go to the Journal Capital office on Kihekah Avenue and get bundles of papers. Phil and I would fold them into five-point throwing projectiles and fill two canvas bags that we hung over the Ford’s hood ornament. We each sat on a fender and competed for distance and accuracy as we banged the papers off the porches of our neighbors who sometimes complained to our parents. 

I did not read the Journal Capital then and never had any inclination at age 11 to write a column in it. However, I do remember my mother and father sitting at the kitchen table and laughing at Glen’s witty sayings in his regular column. I still remember Mom and Dad laughing out loud when Glen complained that modern science seemed to be able to create hand warmers and foot warmers but for some reason could not come up with a toilet seat warmer. Gentle Readers, that was almost 70 years ago and, while we are now on our way to Mars, we still have not cracked the code on toilet seats. However, we seem to still be sending vast amounts of aid to keep the Russians on their heels.

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