Best Management
Practices: where to start?

For some pollutants, developing
numeric discharge limits may not
be feasible.

The NPDES and Pretreatment
regulations allow for Best
Management Practices (BMPs) to
be used in lieu of numeric, end-of-
pipe limits in such instances. See 40
CFR 122.44(k) and 40CFR
403.5(c)(4).

EPA has published guidance on
implementing BMPs for NPDES and
Pretreatment:

•	EPA Guidance for Developing
Best Management Practices

https://www3.epa.gOv/npdes/p
ubs/owm0274,pdf

•	Chapter 9 of the NPDES Permit
Writer's Manual

https://www.epa.gov/sites/defa
ult/files/2015-

09/documents/pwm chapt 09.
pdf

•	Guides to Pollution Prevention:
Municipal Pretreatment
Programs

https://www3.epa. gov/npdes/p
ubs/pretreatment mun guide.p
df

•	Pretreatment Streamlining Rule
Fact Sheet 7.0: Best
Management Practices

https://www.epa.gov/sites/defa
ult/files/2015-

10/documents/pretreatment st
reamlining 7.0.pdf

PFAS in Industrial Wastewater

PFAS can be found in the wastewater discharges of certain industrial facilities
subject to NPDES permitting or pretreatment requirements (U.S. EPA, 2021).

Permit writers and pretreatment coordinators are encouraged to include PFAS
monitoring in permits for facilities where PFAS are suspected of being present in
the discharge. For some facilities where PFAS are found, it may be appropriate to
require permit limits. In some cases, numeric discharge limits based on treatment
technologies using granular activated carbon, ion exchange resins, reverse
osmosis may be appropriate, but for others, pollution prevention practices and
BMPs may be more appropriate.

Permit writers and pretreatment coordinators have observed some of the
following pollution prevention practices for industries in their state or service
area.

Chrome Finishing

PFAS can be found in the effluent discharged from chrome plating facilities due
to the use of PFAS-containing chemical fume suppressants used primarily in
hexavalent chrome plating operations. Many of these facilities discharge to
wastewater treatment plants (U.S. EPA, 2009). According to EPA's Effluent
Guidelines Program Plan 15 published in January 2023, preliminary
investigations by EPA have indicated that some facilities may have the option of
switching operations to trivalent chromium, which does not require the use of
chemical fume suppressants, and that PFAS-free alternatives exist or are in
development for processes
which require hexavalent
chromium (U.S. EPA, 2023).

Additionally, because historic
use of PFOS-containing fume
suppressants is believed to be
a legacy source of PFAS
discharges, some agencies
have found that equipment
replacement has been
necessary to achieve reductions in PFAS concentrations in effluent from these
facilities (Michigan Department of Environment, Great Lakes and Energy, 2020).

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Airports and Firefighting

Work is ongoing to develop fluorine-free alternatives to
Aqueous Film Forming Foam (AFFF) that meet Federal
Aviation Administration and Department of Defense
requirements for aircraft firefighting (U.S. EPA, 2023).

Until fluorine-free foams are available, EPA recommends
that NPDES permits for airports contain BMP provisions
that restrict use of AFFF to emergencies and require
both immediate clean up and collection of PFAS-
contaminated wastewater to prevent discharge to storm

sewer systems and notification of any downstream affected parties of potential discharges.

Recreation

Some commercial products sold for recreational activities, such as ski wax and bicycle lubricants, are

believed to be a source of PFAS found in
groundwater and surface water (National Science
and Technology Council Office of Science and
Technology Policy (NSTC), 2023). Investigations in
Maine and Utah have indicated that ski wax is a
source of groundwater contamination (Carlson &
Tupper, 2020) (Park City Municipal Corporation,
2022). Though the industry has phased out use of
these products, consumers and local retail shops
may continue to use existing stock; illegal
importation of PFAS-containing products has also been observed. Municipally-sponsored take back
programs, consumer awareness and education programs, and training programs for wax or bicycle
technicians are examples of best management practices that have been implemented in impacted
communities (U.S. EPA Office of Enforcement and Compliance Assurance, 2022).

Other Industrial and Commercial Sources

Other industries may have PFAS in their effluent that can
reach surface waters or wastewater treatment plants.

Some of these industries include chemical manufacturing;
semiconductor manufacturing; textile mills; centralized
waste treatment; landfills; pulp, paper and paperboard
manufacturing; and coatings, paint, and varnish
manufacturing. PFAS may also be used as surfactants in
cleaning products used in industrial processes (National
Science and Technology Council Office of Science and
Technology Policy (NSTC), 2023). Permit writers are
encouraged to evaluate the appropriateness of PFAS BMPs at these facilities using the principles below.

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Consumer Products

PFAS can be found in a number of consumer products used by households or commercial
establishments that may be discharged in the domestic wastewater received by POTWs. Since many
relevant federal regulations do not apply to domestic wastewater, pollution prevention education
campaigns targeted at customers are an available tool for cities to reduce PFAS discharges to
wastewater treatment plants. EPA's Safer Choice program is a resource to municipalities for directing
customers to PFAS-free alternatives to many of these products.

State and Municipal Examples of Pollution Prevention

•	In Michigan, the state Department of Environment, Great Lakes and Energy (EGLE) implemented a

targeted analysis of PFAS use in chrome plating facilities. Through their Industrial Pretreatment
Program, the state worked with chrome platers to reduce PFAS discharges both through the
installation of pretreatment systems and adoption of BMPs.

•	in California, the State Water Resources Control Board issued Order WQ 2019-0045-DWQ to
chrome plating facilities identified by the
state, requesting the completion of a
questionnaire and development of a site
work plan.

•	In Park City, Utah, the municipality has
partnered with local organizations to
raise awareness of PFAS in ski wax and

implement take back programs for
consumers.

•	In Colorado, the state has issued Policy
20-1, Policy for Interpreting the
Narrative Water Quality Standards for Per- and Polyfluoroalkyl Substances (PFAS). One draft
permit that has been public noticed under this policy includes provisions for conducting site
investigations and submitting a report about PFAS on site.

•	The state of Vermont partnered with EPA on a project to collaborate with the metal finishing and
aerospace industries in the state to apply pollution prevention principles to reduce and eliminate
PFAS discharges to wastewater treatment plants. The project involved training and education to
businesses on optimizing operations and transitioning to PFAS-free alternatives. A final report on
the project is expected in June 2023.

Implementing Best Management Practices: Develop a BMP Plan

When permitting a facility, permit writers and pretreatment coordinators should evaluate whether PFAS
are currently used, and whether site-specific BMPs and pollution prevention strategies are appropriate.
If so, work with the permittee to develop a BMP plan for the site. Elements of a BMP plan are described
below.

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BMP Plan Development

S Are PFAS used at this facility? Consider both industrial uses as well as cleaning, pest

management, emergency (fire) response applications at the site.

S Have PFAS historically been used at this facility?

S If the answer is uncertain, permit writers can also consider a permit requirement that a site
investigation or report be submitted that documents any uses or inventory of PFAS-containing
chemicals on site.

If PFAS are present in the facility's discharge, consider the following permit language:

Within 6 months of the effective date of the permit, the facility shall provide an evaluation of
whether the facility uses or has historically used any products containing PFAS, whether use of those
products or legacy contamination reasonably can be reduced or eliminated, and a plan to implement
those steps.

If the written evaluation determines that BMPs and pollution prevention strategies are appropriate,
a BMP plan for the site should be developed, which may include:

J Product substitution and replacement. Do alternatives to PFAS exist? Permittee should

document basis for requiring PFAS and why alternatives are not available.

J Good operating and housekeeping practices, such as:
o Chemical inventory regularly maintained.

o Safe chemical storage, such as secondary containment and placement away from floor
drains that lead to WWTP or storm drain, including legacy PFAS chemicals during
product substitution,
o Replacement of contaminated equipment, if source of legacy PFAS discharges,
o Containing or reusing contaminated equipment in between uses, rather than rinse and
disposal.

o Containing contaminated rinse water of equipment, employee handwashing, or
protective gear.

o Proper operation and maintenance of equipment to avoid malfunction and accidental
discharge.

o Emergency response plan that addresses spill containment and cleanup of PFAS.
o Employee education and training on good housekeeping, operations, and emergency
response.

o Proper management/disposal of legacy PFAS chemicals.

S Solid waste disposal as a result of implementing best practices (such as with equipment
replacement) may be out of scope of NPDES or pretreatment requirements, but may be
considered as part of a holistic agency PFAS response.

/ BMP plan should require an annual certification statement and maintenance of records related
to adherence to BMPs.

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References

Carlson, G, L,, & Tupper, S. (2020). Ski wax use contributes to environmental contamination by per- and
polyfluoroalkyl substances. Chemosphere.

Michigan Department of Environment, Great Lakes and Energy. (2020, June). Targeted and Nontargeted Analysis of
PFA.S in Fume Suppressant Products at Chrome Plating Facilities. Retrieved from

https://www.michigan.gov/egle/-/media/Project/Websites/egle/Documents/Programs/WRD/IPP/pfas-
chrome-

plating.pdf?rev=68a2ffa0383b40ala324da40eb9ab788&hash=D8CBE5902F74D769AFCB90C67022B236

National Science and Technology Council Office of Science and Technology Policy (NSTC). (2023). PER-AND
POLYFLUOROALKYL SUBSTANCES (PFAS) REPORT. Retrieved from https://www.whitehouse.gov/wp-
content/uploads/2023/03/OSTP-March-2023-PFAS-Report.pdf

Park City Municipal Corporation. (2022). PFAS in Drinking Water. Retrieved from

https://www.parkcity.org/home/showpublisheddocument/72378/637920896072230000

U.S. EPA. (2009). PFOS CHROMIUM ELECTROPLA.TER STUDY. Retrieved from

https://nepis.epa.gov/Exe/ZyPDF,cgi/P100ZE21.PDF?Dockey=PlQ0ZE21,PDF

U.S. EPA. (2021). Multi-Industry Per- and Polyfluoroalkyl Substances (PFAS) Study - 2021 Preliminary Report.
Retrieved from https://www.epa.gov/system/files/documents/2021-09/multi-industry-pfas-
study_preliminary-2021-report_508_2021.Q9.08.pdf

U.S. EPA. (2023). Effluent Guidelines Program Plan 15. Retrieved from

https://www.epa.gov/system/files/documents/2023-01/11143_ELG%20Plan%2015_508.pdf

U.S. EPA Office of Enforcement and Compliance Assurance. (2022). EPA Enforcement Alert: Violations May Put Ski
Wax Users at Risk from Illegal Perfluoroalkyl Substances. Retrieved from
https://www.epa.gov/system/files/documents/2022-01/pfasskiwax.pdf

Disclaimer:

This document provides general information about the flexibilities permit writers and pretreatment
coordinators have in regulating industrial PFAS discharges. While this document cites statutes and
regulations that contain requirements applicable to these discharges, it does itself not impose legally
binding requirements on EPA, states, authorized tribes, other regulatory authorities, or the regulated
community. EPA, states, authorized tribes, and other decision makers may adopt approaches on a
case-by-case basis that differ from those provided in this document, as appropriate and consistent
with statutory and regulatory requirements. Also, EPA may update this document as new scientific
and technical information becomes available.

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