Presentation_PFAS-02B-SWStandards_Implementation_Grzyb

Potentially Affected Sources andSurface Water Rulemaking Implementation Requirements
January 10, 2024
Julie A. Grzyb
Water Quality Committee
Discussion Topics
•EPA's Proposed Drinking Water Standards
•Plan for Addressing and Implementing PFAS Surface Water Standards
with a focus on protecting Drinking Water Supplies
•Source Types
•Expected PFAS discharge levels
•Implementation approach and timeline
•Stakeholder input
2
EPA Proposed Primary Drinking Water Standards for PFAS
•Expected to be finalized in early 2023. Compliance requirement effective 2026.
•Public Water Supply Systems (PWS)
•Supplies drinking water to 9,094,537 North Carolinians.
•459 PWS receive source water from surface water bodies.
•41% of large PWS (>10,000 people) exceed EPA proposed standards.
•Proposed Surface Water Quality Standards
•Reducing PFAS in surface water discharges will reduce clean up requirements and costs for PWS.
•Compliments EPA's drinking water standards that are under state authority.
3
Permit Programs Affected by Surface Water Quality StandardsNational Pollutant Discharge Elimination System (NPDES) Permits
*recognized as PFAS contributors in EPA’s memo dated 2022
Industrial
Dischargers with
Individual Permits
(Major and Minor)
POTWs with
Pretreatment
Programs (Major and
Minor)
Major POTWs
without
Pretreatment
programs
Major and Minor
Industrial Process & Commercial Facilities
not Targeted by EPA
Groundwater Remediation
Water Treatment
(RO or IX w/reject
wastewaters)
Identification of Potentially Affected Industries
5
organic chemicals, plastics & synthetic fibers
metal finishing Electroplating electric and electronic components landfills
pulp, paper & paperboard leather tanning & finishing
plastics molding & forming; textile mills
paint formulating airports
Addressing PFAS Discharges in NPDES Permits and Through Pretreatment Program and Monitoring Programs
EPA Guidance Issued December 5, 2022
Potentially Affected Industrial Dischargers with
Individual Permits (Majors)
6
70%
30%
57
PFAS
IndustryNon-PFAS
Industry
Breakdown of PFAS and Non-PFAS Industries
Potentially Affected POTWs with Pretreatment Programs
(Majors)
7
36%
64%
Breakdown of POTWs with Pretreatment
Programs that Receive Discharge from Potential
PFAS Significant Industrial Users (SIU)s
133
Potential
PFAS
SIUs
Non-PFAS
SIU
Breakdown of SIUs
65%
35%
606 Non-
PFAS SIU
Potential
PFAS SIUs
Summary of Detections of PFAS with Proposed Standards
Permit
Type
# of Facilities
Sampled
Number of Facilities with Specified Detections
PFAS Detections Above Proposed Standards
None GenX PFHxS PFNA PFOA PFOS
Industrial
Major 15 5 2 3 2 9 8
Industrial
Minor 3 2 1 1 1 1 1
POTW Major w/
Pretreatment 39 0 2 21 23 37 39
Summary of Concentration of PFAS
There is currently no sampling data available for POTW Minors with Pretreatment
0
50
100
150
200
250
GenX PFBA PFBS PFHxA PFHxS PFNA PFOA PFOS
Co
n
c
e
n
t
r
a
t
i
o
n

(
p
p
t
)
PFAS
Average Concentrations
Industrial Major (n=15)Industrial Minor (n=1)POTW Major with PT (n=39)
Concentration Ranges of PFAS
0.01
0.1
1
10
100
1000
GenX PFBA PFBS PFHxA PFHxS PFNA PFOA PFOS
Co
n
c
e
n
t
r
a
t
i
o
n

(
p
p
t
)
PFAS
Concentration RangesPermit Type Minimum Maximum
Industrial Majors
Industrial Minors
POTW Majors w/ Pretreat
Max
Min
POTWs with pretreatment programs
PFAS SIU Sector Types
12
Total # SIUs
214
8 POTWs collectively
receives discharges
from 27% of the SIUs
that are suspected to
be associated with
PFAS.
Potential Industries with PFAS wastewaters
NPDES PFAS Implementation Plan•Jan. 2024: Holding multiple Stakeholders meetings to discuss implementation plan and learn their concerns.
Outline on Initial plan goals:
•Jan. 2024 – Dec. 2025:PFAS Assessment Monitoring
o Quarterly PFAS Assessment Monitoring at Industrial majors and POTWs with pretreatment programs using recommended EPA test
methods outlined in EPA's Dec. 2022 memo. Gives POTWs an opportunity to assess PFAS levels from Significant industrial users.
o Encourage source reduction, BMPs and minimization strategies
o For permits being renewed, NPDES will add a PFAS permit condition requiring permittees known to discharge PFAS, to sample PFAS using
EPA test method 1633 within 6 months after final publication of the final method (not anticipated to occur till Dec. 2025).
o New discharges with significant levels of PFAS will be required to achieve PFAS levels protective of downstream drinking water supplies(i. e.
Landfills treating leachate, mega sites, remediation sites).
•Nov. 2024: EMC Deciding on PFAS Rule Adoption
•Dec. 2025: Anticipated Publication of EPA test method 1633 in CFR
•July 2026 – 2028: Certified Monitoring Period
o Add PFAS monitoring requirements to targeted (based on preliminary assessment monitoring results) minor industrial permits and major/minor POTWs
o Industrial sites include groundwater remediation facilities and Water Treatment plants
o Encourage source reduction, BMPs and minimization strategies
•July 2027 – 2033: Effluent limits and Compliance Schedules added to Industrial majors when certified data shows reasonable potential to violate WQSs.
•Jan. 2028 – 2034: Effluent limits and Compliance Schedules added to POTWs permits with pretreatment programs.
o Minor industrial users with elevated PFAS levels will be assessed for limits and monitoring as permits are renewed.
NPDES PFAS Implementation Plan
•Jan. 2033:
o Minor POTWs - (with no pretreatment program) will not be considered for PFAS effluent limits till 2033 unless shown to have
elevated levels of PFAS and the discharge is impacting downstream water supplies (initial efforts will be to look for source
reductions before requiring treatment)
o 100 % domestic wastewater permittees will not be assessed for PFAS effluent limits unless shown to have elevated levels of
PFAS and the discharge is impacting downstream water supplies(initial efforts will be to look for source reductions before
requiring treatment)
o Small discharges < 30,000 gpd will be considered de minimis unless mass loading is impacting downstream water supplies
o WTPs will be required to test for PFAS, effluent concentrations should not exceed Standards or intake concentrations, discuss
approach with stakeholders
Note:
Implementation Schedule is dependent on a wastewater test method published in the CFR by EPA by the end of
2025 (dates may be moved forward based on final publication).
When proposed health based 02B .0208 standards are below detection levels, permit effluent limits will be
based on national lab validation PQLs/MRLs ( i.e. sufficiently sensitive test methods); however, effluent limits can
be lowered upon permit renewals (every five years) to comply with state std. if test method
PQLs/MRLs improve.
Surface Water PFAS Implementation Plan Contacts
16
Julie Grzyb, Deputy Director DWR
919-707-9147
[e-mail]
Michael Montebello, NPDES Branch Manager, DWR
919-707-3624
[e-mail]