CTDEEP’s Industrial Wastewater PFAS Roadmap 2.0: What Facilities Should Know

Connecticut DEEP’s recently released Industrial Wastewater PFAS Roadmap 2.0 provides a clearer picture of how the state expects to address PFAS through its industrial wastewater permitting programs.

The Roadmap is not a new permit or regulation. Instead, it outlines DEEP’s evolving approach to PFAS and signals a growing emphasis on screening, source identification, source reduction, monitoring, and, where appropriate, treatment controls.

For Connecticut manufacturers and other industrial dischargers, the takeaway is straightforward: understanding where PFAS may be present in your operations and wastewater is becoming increasingly important.

PFAS requirements are already appearing in some of Connecticut’s industrial wastewater permitting programs, while other requirements are still being developed.

Depending on a facility’s operations, wastewater characteristics, and permit, PFAS considerations may include:

• Sampling and monitoring
• Evaluation of current and historical PFAS sources
• Source identification and reduction planning
• Review of chemicals, raw materials, and processes
• Additional reporting or permit conditions
• Treatment or other controls where warranted

DEEP is also continuing to update its individual wastewater permitting process to incorporate PFAS considerations for certain industries and facilities where PFAS is known or suspected. Roadmap 2.0 gives facilities an important indication of where the program is headed, even where specific permit requirements have not yet been established.

Finding PFAS in a wastewater sample is only the beginning. The more important question is often:
Where is it coming from?

PFAS may be associated with raw materials, coatings, process chemicals, cleaning products, equipment, historical operations, or other sources that are not immediately obvious. Understanding how those materials connect to individual wastewater streams can help facilities identify practical opportunities to reduce PFAS before more complex or costly controls are needed.

That is why source identification and reduction are such an important part of DEEP’s evolving strategy.

Facilities do not need to wait for a new permit condition to begin preparing.

Now is a good time to:

• Review existing wastewater permits and upcoming renewal schedules.
•  Identify processes and materials that may contain or contribute PFAS.
• Understand how individual process streams connect to wastewater discharges.
• Organize existing chemical-use, process, and sampling information.
• Identify data gaps that could make future source evaluations more difficult.
• Consider practical opportunities to eliminate or reduce PFAS at the source.

Early planning does not necessarily mean immediately beginning a sampling or treatment program. It means understanding your facility well enough to respond efficiently as regulatory expectations continue to develop.

PFAS regulation is also evolving on the municipal side.

CTDEEP is developing a separate General Permit for PFAS Monitoring for certain municipal and private domestic wastewater treatment facilities. That permit has not yet been issued, but DEEP has indicated that it is expected to focus on monitoring PFAS in wastewater systems and identifying potential upstream contributors.

For industrial and commercial users that discharge to municipal sewer systems, this is another reason to understand potential PFAS sources now. As wastewater utilities begin gathering more information about PFAS entering their systems, upstream source identification is likely to become increasingly important.

PFAS requirements will continue to evolve, but facilities can take meaningful steps now to better understand their exposure and prepare for future permitting and compliance needs.

Fuss & O’Neill’s environmental compliance and wastewater professionals can assist with:

• PFAS sampling and monitoring strategies
• Source identification and reduction evaluations
• Industrial wastewater and pretreatment assessments
• Regulatory and permit interpretation
• Treatment evaluations
• Implementation and budget planning

Our work with both industrial dischargers and wastewater systems gives us a practical perspective on PFAS from the source through collection and treatment.