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Regulatory Updates

EPA Publishes Effluent Guidelines Program Plan 15

Mark Robinson | February 14, 2023

Under the Clean Water Act (CWA), the Environmental Protection Agency (EPA) publishes its plan for updating its effluent limitations guidelines every two years. EPA uses the plan to summarize research on various industry sectors’ wastewater discharges, propose associated pretreatment standards and incorporate public comment on proposed rulemaking to update effluent limitations guidelines and pretreatment standards for certain industry sectors. EPA also issues a “preliminary plan” during the off-cycle years to track developments and obtain public comment.

EPA Actions

Plan 15, announced in the January 31, 2023 Federal Register and available at Current Effluent Guidelines Program Plan | US EPA, follows the EPA format for recommending rulemaking, summarizing studies of discharges and available treatment technologies and updating status for rulemaking from prior plans. Like Plan 14 and Preliminary Plan 15 (2021), the focus of the evaluation and rulemaking process is per- and polyfluoroalkyl substances (PFAS) discharges.

  1. EPA recommended revisions to the effluent guidelines and standards for Landfills Category under 40 CFR 445, based on the study of landfill leachate discharges and their potential for PFAS contributions to surface waters or publicly owned treatment works (POTWs).
  2. EPA will continue to study Textile Mills Category under 40 CFR 410, adding a mandatory questionnaire to gather data from mills nationwide.
  3. EPA will begin collecting nationwide data on industrial discharges of PFAS to POTWs from industrial sources, including some industrial categories that were recently reviewed. This study would provide more clarity about sources of PFAS wastewater and help POTWs assess the need for control measures at the source.

EPA announced in Plan 15 that no further action was being proposed for the Electrical and Electronic Components (E&EC) Category (40 CFR part 469); the Pulp, Paper and Paperboard Category (40 CFR part 430); and airports. The nationwide POTW Influent Study above would be used to monitor PFAS use and discharges from these categories/sources.

EPA included updates to existing rulemaking in the Plan for Steam Electric Power Generating, Meat and Poultry Products, Organic Chemicals, Plastics and Synthetic Fibers and Metal Finishing and Electroplating Categories.

What Should You Do?

Evaluate: Determine your risk profile for PFAS. Identify and find replacements for PFAS sources.

Monitor: Be aware of Federal and State developments for rulemaking and of studies for your industrial sector.

Plan: As rulemaking focuses on treatment at the source, follow advances in analytical methods and treatment technologies.

For more information, contact our expert below.

Mark Robinson

Mark B. Robinson, PE, CHMM, CPEA is a Market Director for TRC and sits in the Atlanta area. He has over 30 years in consulting and industry EHS experience.  He has managed a wide variety of industrial sector projects and programs, including EHS compliance auditing for airbag manufacturers, dairy and food manufacturing/distribution and pulp/paper mills; managing a portfolio of SPCC/FRPs for telecom and petroleum terminals; and complex regulatory reporting across various industries.

For the 2020 TSCA CDR season, he supported reporting for the oil and gas industry including refining, asphalt, and import/export; pulp and paper mills; cement plants; and metals smelting industries.
Contact Mark at

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