WGF Comments on DNR’s PFOAS Guidance

Responding to WDNR Draft Guidance for PFOA and PFAS in Water

The Wisconsin Department of Natural Resources (WDNR) is developing guidance for minimization plans of wastewater treatment systems regarding two of the most common forms of per- and polyfluoroalkyl substances, commonly known as PFAS. Those two forms include perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). The purpose of these minimization plans is to improve the quality of water coming out of the wastewater treatment systems and better meet water quality standards.

At Wisconsin’s Green Fire (WGF), our Contaminants of Emerging Concern (CEC) Work Group has been reviewing the WDNR’s guidance docs to offer suggestions for improving how Wisconsin deals with these chemicals in surface water, including for public and private drinking water systems.

Our Comment Letter to the WDNR

WGF Comments on PFOAS Minimization Plan Guide, September 12, 2024

We submitted our comment letter on the draft guidance docs to the WDNR on September 12, 2024.

Read WGF’s comment letter here.

Three of our main comments detail:

1. Weaknesses in how the guidance handles PFOA and PFOS within wastewater treatment systems, like coatings on sewer pipes.
2. Need for clarity in how “site-specific literature reviews” and “finger printing” technologies for detecting and treating PFOA and PFOS in wastewater treatment plants.
3. Need for expanded discussion of potential PFAS sources.

Our letter goes on to describe details of PFOA and PFOS minimization for:

• Landfills
• Airports
• Firefighting Training Centers
• Fire Suppression Systems
• Pulp/Paper Manufacturers
• Metal Finishers
• Plastics Industry
• Electronics
• Source Water
• Domestic Sources

One of our final points supports adding additional PFAS, including chemicals like PFHxS, PFNA, and the newer class of PFAS chemicals known as GenX to Wisconsin’s surface water quality standards.

Read examples of WGF’s prior work on PFAS:

Publications and Presentations:

• New Opportunities Now Paper: PFAS 2.0
• 2023 PFAS Conference 
• PFAS: Forever Chemicals in Wisconsin Webinar Recording 
• PFAS: Forever Chemicals in Wisconsin — Wisconsin’s Green Fire Opportunities Now 2021-2023 Report on PFAS

Blog posts:

• PFAS Update: Status of the $125M in “PFAS Trust Fund”
• PFAS News from Gov. Evers and the EPA
• Discussing PFAS with Gov. Evers
• WGF Statement on WDNR’s request for JFC action on PFAS funding
• Senate Passes Imperfect PFAS Bill
• Wisconsin’s Green Fire and Partners Equip Local Leaders to Address PFAS in Wisconsin Communities 

Learn more about the Contaminants of Emerging Concern Work Group here.

If our work on PFAS, clean water, or other topics mentioned here inspired or informed you, please consider supporting our work with a donation to Wisconsin’s Green Fire. An annual gift of any amount makes you a member. Thank you!