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INDUSTRIAL WASTEWATER DISCHARGERS – PFAS QUESTIONNAIRE

Posted on June 16th, 2021

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In March 2021, the New Jersey Department of Environmental Protection (NJDEP) required all industrial dischargers (facilities with Category B and Category L New Jersey Pollutant Discharge Elimination System [NJPDES] permits) to evaluate potential historic and current sources of per- and polyfluoroalkyl substances (PFAS) and to complete a survey.

PFAS are manmade chemicals historically used as a processing aid in the manufacturing of high-performance plastics that are resistant to harsh chemicals and high temperatures. They are also found in aqueous film forming foams, surfactants, and stain resistant coatings, and are used in metal plating and finishing.  Until recently, PFAS were not regulated. After decades of widespread unregulated use, and the fact that PFAS chemicals are practically indestructible, PFAS are essentially ubiquitous across the planet. PFAS remediation technologies are in their infancy and several remedial technologies are under development.  For more information on the development of PFAS remedial technologies, see our previous blog here: Bioremediation Spotlight: New Jersey Native Bacteria Discovered to Breakdown Forever Chemicals.

Since these chemicals are persistent, they may be present long after PFAS containing chemicals were used. Because of the risks to public health and safety and the environment, and increasing public and regulatory interest in PFAS chemicals, the Department is looking for ways to reduce the amount of these chemicals entering the environment through direct discharges or through discharges from water treatment facilities.

While no sampling for PFAS is required at this time, the NJDEP will likely require any sites where there was the potential for historic use or storage of these compounds to investigate probable sources and reduce/eliminate the sources found (via product substitution, operational controls, or treatment). If your site did, or may have, used these compounds in the past, you should consult with your LSRP regarding the need to sample at your site.

The survey responses are due to the NJDEP by June 16, 2021 by submitting the answers to the questions via an upload link. The NJDEP may issue fines to facilities for failure to respond.  A courtesy copy of the NJDEP request for information and a list of questions, as well as frequently asked questions, can be found here: https://www.nj.gov/dep/dwq/pfas.htm.

If PFAS compounds were potentially used at your industrial facility in the past, JMS can assist you in determining the need for sampling and any other PFAS questions you may have. Please contact us at 908-218-0066 or consult@jmsorge.com to learn how we can assist you through the process.

For more information on PFAS, refer to these previous JMS blogs:

PFOA and PFAS… It’s Not Going Away – June 2, 2020

PFAS Goes to Congress – August 30, 2019

Further Regulatory Updates: PFAS – July 17, 2019

USEPA Announces Per- and Polyfluoroalkyl Substances (PFAS) Action Plan – March 29, 2019

Regulatory Update: PFAS – January 25, 2019

New Emerging Contaminants Creating Potential Problems for Parties Remediating Sites – October 16, 2018

Keep an eye out for future JMS blogs on the status of PFAS remediation research!

 

Alison Kokorsky, LSRP

Senior Manager


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