Sarah Stoneking

December 19, 2023

Client alert: What is the proposed USEPA textile mills industry PFAS information collection request and how might it affect you?

The US Environmental Protection Agency (USEPA) has issued notice that it plans to submit a data collection request to textile manufacturing facilities to collect information relating to the potential presence of per- and polyfluoroalkyl substances (PFAS) in process wastewater discharges from these facilities. In this article, we provide a summary of the proposed textile mills industry data collection plan. 

Toxic water running in concrete drainpipe towards the river
facebook linkedin twitter
Comments are being solicited until January 29, 2024, and can be submitted at: www.regulations.gov.
Who will receive information requests?
USEPA is targeting approximately 2,200 textile manufacturing facilities within the US. It is anticipated to focus on facilities that perform one or more of the following operations and discharge process wastewater to surface waters or to publicly owned treatment works (POTWs):
  • Wool scouring
  • Wool finishing
  • Yarn and unfinished fabric manufacturing
  • Woven fabric finishing
  • Knit fabric finishing
  • Carpet finishing
  • Nonwoven textile products of wool, cotton, synthetics, or blends of such fabrics
Are responses to the information request, if received, mandatory?
Yes, responses to the questionnaire will be mandatory.
What kind of information will be requested?
Although the survey has not been released, respondents can expect USEPA to collect information regarding:
  • The type of manufacturing activities conducted
  • Whether PFAS are used in the facility processes and if so, which
  • Volumes of wastewater produced and type of wastewater treatment prior to discharge, including confidential business information (CBI) relating to PFAS use
Although not clearly stated in the USEPA announcement, it appears that the questionnaire may request information about both current and historical operations. Respondents may mark any claimed confidential responses as CBI.
What will the USEPA do with the questionnaire responses?
USEPA reports that it plans to review the responses and identify approximately 20 facilities for which sampling of wastewater for PFAS will be required. Responses may also support USEPA efforts to develop and propose new regulations if deemed appropriate.
What will the USEPA do with the wastewater discharge data?
USEPA plans to estimate current pollutant mass loads and achievable reductions for available technologies for the industry and to determine if the effluent limitations guidelines (ELGs) limiting pollutant discharges from industrial point source categories under the Clean Water Act should be revised.
How can clients prepare, if affected?
  1. Review the proposed actions and submit comments, if appropriate
  2. Form your team to assist you in responding. Typically, this includes in-house key personnel, environmental consultants, and counsel.
  3. Perform an assessment of risks and liabilities with your team
  4. Form a strategic plan to address identified risks and liabilities (e.g., substitution plan, modifications to the existing process wastewater treatment system)
Ramboll can help
For more than two decades, Ramboll has helped clients around the world resolve their most critical PFAS issues. Specific to this issue, we can help:
  • Evaluate potential risks associated with PFAS and preparation of environmental liability cost estimates
  • Develop PFAS substitution plans
  • Develop and implement sampling strategies for industrial materials, processes, raw materials, and wastes
  • PFAS supply chain/operational assessments
  • Conduct treatability studies evaluating specific PFAS removal efficacies for commercially available treatment technologies
  • Develop PFAS discharge reduction programs including permit support, technology evaluations, engineering, and construction management
  • Evaluate and implement wastewater minimization actions
  • Environmental support for legal matters relating to the discharge of PFAS
For specific advice relative to your situation, contact Ramboll: sstoneking@ramboll.com or pfas@ramboll.com.
> Click here for more information on Ramboll's PFAS services

Want to know more?

  • Sarah E. Stoneking

    Principal

    +1 703-516-2407