Does EPA Endorse PFAS Minimization Plans for Industrial Facilities?

The primary purpose of PFAS minimization plans is to prevent contamination from entering public wastewater treatment systems and community water bodies (visual source: YouTube/USEPA).

The purpose of waste minimization plans is to reduce or eliminate the release of per- and polyfluoroalkyl substances (PFAS) from industrial and commercial sources before they contaminate public water systems or the environment. These plans are a proactive strategy to manage PFAS at the source, which minimizes exposure risks to communities and the environment before contamination becomes widespread or expensive to clean up.

Key Goals of Minimization Plans

1. Identify sources of pollutant use or generation within industrial operations.

2. Implement best management practices (BMPs) to reduce or eliminate PFAS discharges to air, water, and land.

3. Prevent future liabilities and minimize long-term remediation costs for downstream water users.

4. Protect downstream drinking water sources and aquatic ecosystems.

5. Support compliance with regulatory requirements, including future limits.

Pollution prevention (P2), also known as source reduction, is any practice that reduces, eliminates, or prevents pollution at its source prior to recycling, treatment, or disposal. - USEPA

Source Reduction Techniques

These are the top source reduction techniques determined by USEPA after two decades of monitoring and measurement. The list is in descending order of effectiveness. In some cases, higher-ranked alternatives may not be feasible in every operating context.

1. Material Substitutions & Modifications

2. Product Modifications

3. Process & Equipment Modifications

4. Operating Practices & Training

5. Inventory & Material Management

EPA’s Position on PFAS Minimization Plans

The U.S. Environmental Protection Agency (EPA) endorses source control and pollution prevention measures, including PFAS minimization plans, especially as part of its PFAS Strategic Roadmap.

In several contexts, the EPA has promoted or required PFAS minimization strategies:

• National Pollutant Discharge Elimination System (NPDES) Permits: EPA issued guidance in April 2022 recommending that states and regions include PFAS minimization plans in NPDES permits for industrial and municipal dischargers, even in cases where PFAS is not yet regulated with numeric limits. This helps prevent PFAS from entering surface waters and drinking water supplies.

  
  

• Pre-treatment Programs: For industrial users that send wastewater to municipal treatment plants (Municipal Treatment Works, or POTWs), the EPA encourages the use of pre-treatment controls to minimize PFAS discharges into the sewer system, recognizing that POTWs often struggle to treat PFAS effectively.

  
  

• Pollution Prevention (P2) Tools: Through the Toxic Substances Control Act (TSCA) and P2 programs, the EPA promotes substitution of PFAS chemicals with safer alternatives and encourages voluntary minimization efforts by industry.

PFAS Minimization Plans Are a Proactive Approach

Minimization plans are a preventive approach that EPA supports as part of a broader strategy to protect drinking water sources, reduce exposure risks, and encourage responsible industry practices. They are particularly important before PFAS reaches water bodies or public wastewater treatment systems, when mitigation is far more difficult and costly.

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JD Solomon is the founder of JD Solomon, Inc., the creator of the FINESSE fishbone diagram®, and the co-creator of the SOAP criticality method^©. He is the author of Communicating Reliability, Risk & Resiliency to Decision Makers: How to Get Your Boss’s Boss to Understand and Facilitating with FINESSE: A Guide to Successful Business Solutions.