Corporate Correspondent Memoranda

CC-21-011: EPA Water – Notice of Availability – Preliminary Effluent Guidelines Program Plan 15

In the September 14, 2021, issue of the Federal Register, EPA announced the availability of its Preliminary Effluent Guidelines Program Plan 15. Publication of plans under EPA’s Effluent Limitations Guidelines (ELG) program is routine and a means for justifying the establishment or revision of ELGs for industrial point source categories (PSCs). A particular and important focus of the Preliminary Plan 15 is the need to regulate Per- and Polyfluoroalkyl Substances (PFAS) for certain PSCs. EPA considered, but ultimately chose not to pursue, ELGs for PFAS for the Pulp, Paper and Paperboard category. Furthermore, neither the Timber Products Processing nor the Pulp, Paper and Paperboard categories were identified as a priority for revised ELGs under Preliminary Plan 15.

EPA is considering making “refinements” to its process for prioritizing PSCs for new or revised effluent guidelines, and NCASI may submit comments on this topic. Comments are due by October 14, 2021.

This information will be of interest to all companies that discharge wastewater.