CTDEEP Releases Water Pollution Control Facility (WPCF) PFAS Report

On June 8th, 2023, the Connecticut Department of Energy and Environmental Protection (CTDEEP) published its final study on PFAS contamination detected in the state’s water pollution control facilities (WPCFs). The study identified:

• The presence of 29 different PFAS compounds in at least one water or sludge sample; and
• The presence of 19 different PFAS compounds in samples from fish tissues.  

CTDEEP has indicated that they will implement PFAS monitoring requirements at all WPCF and PFAS monitoring will be a requirement of NPDES permits (CTDEEP's Per- and Polyfluoroalkyl Substances (PFAS) in Municipal Wastewater Treatment Facilities page). The trigger for PFAS monitoring will be dependent on EPA’s final approval of their multimedia analytical Method 1633. The fourth draft of Method 1633 was released in late July 2023, and the final version is expected later this year or early 2024.   

During this interim final approval period, WPCF should assess their funding requirements to implement the proposed sampling requirements.  Other industries should evaluate their potential risk and financial exposure related to 1) the addition of PFAS sampling and analyses as part of NPDES permitting, and 2) current or future discharges to WPCFs to assess for potential PFAS contribution to a WPCF, and future requirements in conjunction with issuing new or renewals of discharge permits.