U.S. EPA issues interim strategy memo for PFAS

The U.S. Environmental Protection Agency (EPA) recently issued an interim strategy memo providing recommendations for addressing per- and polyflouroalkyl substances (PFAS) in federally issued National Pollutant Discharge Elimination System (NPDES) permits. While the interim strategy only applies to select states (Massachusetts, New Hampshire, and New Mexico), the District of Columbia, most U.S. territories including Puerto Rico, Indian country, and certain federal facilities, the memo suggests that the strategy also serves as an interim guide for permitting across all ten EPA Regions.

The EPA’s strategy specifically advises that permit writers consider implementing PFAS monitoring at facilities where these chemicals are expected to be present in wastewater discharges. It also encourages the use of best management practices (BMPs) to control or abate PFAS discharges. Potentially impacted facilities include those with individual wastewater permits as well as those covered by MS4 and industrial stormwater permits. The memo also recommends the incorporation of BMPs when appropriate to control or abate PFAS discharge associated with indirect dischargers (such as publicly owned treatment works with NPDES permits).

In coordination with their interim permitting strategy, the EPA is in the process of developing analytical methods for detecting certain PFAS chemicals in wastewater. A total of 40 distinct PFAS chemicals are under consideration, and the agency anticipates finalizing analytical methods in 2021.

The EPA’s news release and interim strategy memo can be found here. To learn more about PFAS and the EPA’s efforts to address PFAS in NPDES permits, please contact Nick Nelson at 952-832-2701 or


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