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PFAS in Wastewater and EPA Proposed Rules: Revising Effluent Limitations Guidelines and Pretreatment Standards

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, February 7, 2023

Recorded event now available

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This CLE webinar will address the U.S. Environmental Protection Agency's (EPA's) proposed rules, which are expected to take several years to come to fruition, aiming to reduce per- and polyfluoroalkyl substances (PFAS) in wastewater discharges by revising effluent limitations guidelines (ELGs) and pretreatment standards. The panel will discuss the EPA's Multi-Industry PFAS 2021 study and findings. The panel will provide guidance for businesses regarding the EPA's current actions in this area and identify and mitigate potential risks associated with PFAS in operations.


The EPA started preliminary work on a pollution rule on the acceptable amount of PFAS discharge into sewage treatment systems and surface waters from "facilities manufacturing PFAS" that are part of the organic chemicals, plastics, and synthetic fibers industries. EPA plans to work on a PFAS pollution rule for industries that perform metal-finishing operations.

Industrial discharges of PFAS have caused significant contamination in places like the Cape Fear River Basin, North Carolina, Parkersburg, West Virginia, Hoosick Falls, New York, and Belmont, Michigan. However, the problem is likely widespread across the United States.

The plan, called the "Preliminary Effluent Guidelines Program Plan 15," identifies actions the EPA plans to take to regulate wastewater pollution. As part of the plan, the agency announced it would craft a rule to limit PFAS discharges from some industries.

In addition to the rulemakings, EPA will conduct "detailed studies" on PFAS in wastewater discharges from landfills and textile and carpet mills. Based on information collected from the preliminary Multi-Industry PFAS Study, EPA identified wastewater discharge from textile and carpet manufacturing industries--a subset of facilities regulated under the textile mills ELGs--as a PFAS source resulting from the use of PFAS chemicals in such operations.

EPA is committed to addressing and ultimately limiting PFAS in industrial wastewater discharges. It is also evident that more industries, not just OCPSF, metal finishing, landfills, and textile mills, will be subject to revised regulations by EPA in the future. With the continued focus on PFAS, businesses should continue to follow EPA's actions in this area and identify and mitigate potential risks associated with PFAS in their operations moving forward.

Listen as our expert panel discusses the rules, the status of current studies on PFAS in wastewater, and how industries can identify potential risks with PFAS to meet future compliance standards.



  1. PFAS prior regulations
  2. Preliminary Effluent Guidelines Program Plan 15
  3. Multi-industry PFAS study
  4. Ongoing comment period
  5. Affected industries
  6. Future regulation


The panel will discuss these and other key topics:

  • What are the limitations on PFAS in the Preliminary Effluent Guidelines Program Plan 15?
  • What industries are most impacted by these rules? What future industries are most likely to be regulated?
  • How can industry affect future regulation of these rules?


DeMeo, Ralph
Ralph A. DeMeo

Guilday Law

Mr. DeMeo practices, inter alia, environmental, land use, and administrative law, with special emphasis in domestic and...  |  Read More

Lee, Thomas
Thomas S. Lee

Bryan Cave Leighton Paisner

Mr. Lee is leader of the firm’s PFAS and Proposition 65 teams. He regularly works with clients in a variety of...  |  Read More

Flesch, Hannah
Hannah M. Flesch

Vinson & Elkins

Ms. Flesch’s principal area of practice is environmental and natural resources law, including environmental...  |  Read More

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