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RE: Comments on Preliminary Effluent Guidelines Program Plan 15, Docket Number

Dear Dr. Flanders,

Clean Water Action/Clean Water Fund appreciates the opportunity to comment on the Environmental Protection Agency’s (EPA) Preliminary Effluent Guidelines Program Plan 15.

We support EPA’s decision to revise Effluent Limitations Guidelines and Standards (ELGs) for the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) category and for chromium electroplating facilities in the Metal Finishing category in order to address discharges of per-and  polyfluoroalkyl substances (PFAS). We also support EPA’s announcement of a new rulemaking to revise the Meat and Poultry Products point source category to address nitrogen and phosphorus pollution, as well as the agency’s intention to publish a proposed supplemental rule to strengthen limits for certain wastewater streams from coal-fired power plants.

While we commend EPA’s efforts, we are seriously concerned that the agency is not moving quickly enough to address PFAS wastewater discharges from other point source categories that  are known or suspected of using these toxic “forever chemicals.” We also believe that EPA should publish a proposed supplemental ELG for coal-fired power plants sooner than the Fall 2022 deadline it announced in July 2021, and that the agency should continue to study and  increase protections from the Oil and Gas Extraction and Centralized Waste Treatment (CWT) categories.

Below we outline recommendation on how the agency can better address PFAS in industrial wastewater discharges, suggested further actions EPA should take to control wastewater discharges from coal-fired power plants and from the oil and gas sector, as well as  recommendations on how the agency should consider environmental justice in its ELGs planning and rulemaking.

Read the full letter here.

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