EPA’s withdrawal of PFAS permit guidance does not automatically change your facility’s permit. Review monitoring duties, waste handling procedures, and renewal questions before changing work on the floor.
Before you cancel a PFAS sample or change a waste pickup, check what your facility still has to do. This review will help you trace requirements to their source, find gaps in daily handling, and prepare clear questions for your permitting agency.
Understand What EPA Withdrew
EPA withdrew its December 2022 guidance on addressing PFAS discharges through wastewater permits and related programs, as reported by The New Lede. PFAS are a large group of chemicals used in some industrial processes and products. The guidance recommended ways for permit writers to address them through monitoring and pollution controls. Its withdrawal changes federal guidance, but it does not automatically rewrite your facility’s permit.
The National Pollutant Discharge Elimination System, or NPDES, is the permit program for regulated discharges to surface waters. Federal rules require permit holders to comply with their permit conditions. Even requesting a permit change does not suspend those conditions. That distinction is spelled out in 40 CFR 122.41.
Gather the Documents That Govern Your Site
Start with the current signed permit and every approved modification. Add applicable stormwater documents, sewer discharge permits, agency orders, and written monitoring requests. If wastewater goes to a municipal treatment plant, include correspondence from that plant’s industrial discharge program. Keep draft renewal language separate from requirements already in effect.
Build a simple review sheet with one row for each PFAS-related task. Record the source document, page number, affected waste stream, deadline, and person responsible. Mark whether the task comes from a permit, another enforceable requirement, a vendor agreement, or an internal decision. Leave uncertain items open for review instead of assuming that every task started with the withdrawn guidance.
Check Each Monitoring Commitment
Compare the review sheet with the sampling calendar and laboratory orders. For each sampling point, confirm the required chemicals, testing method, frequency, reporting deadline, and recipient. Check whether the requirement covers wastewater, stormwater, sludge, or another material. A sample taken from a treatment tank may serve a different purpose than one taken where water leaves the property.
For example, suppose your permit requires quarterly PFAS sampling at a named discharge point. Keep that event scheduled while you clarify whether a change is available. Separately review monthly samples that your company added to investigate a production problem. Before reducing those samples, identify who approved the investigation and whether an agency request or other commitment also applies.
Ask the laboratory to confirm bottle requirements, collection instructions, and turnaround time for the next event. Verify that sample names match the names used in reports. Assign someone to review results promptly, with a backup for absences. A completed lab test still needs a clear handoff to the person responsible for reporting.
Trace Waste From the Process to the Pickup
Walk the affected areas with an operator, maintenance lead, and waste coordinator. Follow each relevant waste stream from the equipment to its tank, drum, tote, or bin. Include rinses, cleanup liquids, spent filters, and sludge where they are part of your process. Record what you know about possible PFAS sources and where information is still missing.
Compare container labels with the waste descriptions used in pickup paperwork. A bin marked “used filters” may not identify which production line supplied them or which vendor approval applies. Use clear internal identification alongside all required labels. Do not remove required markings or change waste classifications based on the guidance withdrawal.
Check the handoffs that happen between shifts. If a tote fills overnight, the next crew needs to know its contents, status, and approved destination. Keep streams separated according to your established procedures while the review is underway. Mixing materials can make later sampling, vendor approval, and record checks harder.
Confirm Vendor Acceptance Before Changing Shipments
A hauler’s pickup confirmation alone does not answer what the receiving facility will accept.
Contact the receiving facility when the review identifies a proposed change in waste composition, testing, or destination. Ask whether its current acceptance requirements call for PFAS information. Request the applicable criteria and approval in writing. A hauler’s pickup confirmation alone does not answer what the receiving facility will accept.
Review the waste profile, which is the description used to evaluate and approve a waste shipment. Compare its process description and supporting test results with what is actually in the containers. If something has changed, resolve the profile update before dispatch. Keep the approval, shipping paperwork, and receipt connected so staff can follow the shipment through completion.
Also check whether revised testing or routing would affect pickup timing. If approval takes longer, estimate available storage space and arrange an acceptable pickup plan early. Give the floor supervisor a clear instruction about which containers are ready to ship. Avoid leaving that decision to the driver at the loading dock.
Prepare Specific Permit Renewal Questions
Use the review sheet to prepare for a conversation with your permit writer or local sewer authority. Point to exact permit sections instead of asking whether PFAS requirements have generally gone away. Include current sampling results and any planned process changes that affect the discussion. Ask these questions before setting the next laboratory budget or rewriting procedures:
- Which existing PFAS conditions remain applicable to this facility?
- What state or local requirements affect our monitoring and reporting?
- What PFAS information will you need with our renewal application?
- Would a proposed monitoring change require a formal permit modification?
- What deadlines should we use for the application and supporting data?
Record the response, the contact’s name, and any follow-up items. An informal conversation can help explain the process, but it should not be treated as an amended permit. Confirm what formal action is needed before implementing a change. Put the next review date on the calendar so unanswered questions do not sit until renewal week.
Approve Procedure Changes and Brief Every Shift
Separate corrections needed now from changes that depend on agency or vendor approval.
Turn the findings into a short action plan with named owners. Separate corrections needed now from changes that depend on agency or vendor approval. For each approved revision, record the reason, effective date, and documents that support it. Keep the previous version available under your document retention procedures.
Brief the people who collect samples, move bins, schedule pickups, and sign paperwork. Tell them exactly which instruction changed and where to find the current version. For example, a revised sampling location should appear on the work instruction and laboratory paperwork before the next collection. Have the supervisor check the first affected handoff to catch mismatched forms or outdated instructions.
Schedule a Demo
A facility review becomes harder when waste profiles, lab reports, and vendor approvals sit in separate inboxes. Staff can spend hours locating records while a pickup or procedure change waits. A Wastebits demo gives your team a chance to evaluate how its waste management tools could support those daily tasks. Bring one real waste stream and ask to walk through three practical benefits:
- Less time searching for waste profiles and supporting documents.
- Clearer handoffs when waste information needs review or approval.
- Easier access to shipment records when preparing for an internal review.
Schedule a Demo to see how the workflow fits your facility. Use your actual paperwork and pickup process to focus the discussion on the gaps your team needs to close.
