Question 1: Could textile mills also be a source of PFASs in drinking water?
[1] So, it would be worthwhile to investigate textile mills for use of PFASs in addition to looking at paper mills.
Based on wastewater flow, the two largest mills are both operated by Milliken.
We do not know whether any of the facilities use and discharge FDA-approved PFASs.
The answer is “no.” EPA has not added any PFAS to either the CWA’s Section 311 Hazardous Substance List or Section 307 Toxic Pollutant List, which would trigger required reporting or chemical testing.
Since PFASs are not on either of these lists, a facility discharging wastewater to surface water does not need to notify the permit writer of the presence of PFASs when applying for or renewing its Clean Water Act (CWA) National Pollutant Discharge Elimination System (NPDES) permit.
Question 3: Are there other benefits to adding PFAS to the CWA Hazardous Substance list?
The answer is “yes.” If PFASs were added to either of the CWA lists, they would be automatically added to the CERLA/Superfund Section 102 Hazardous Substance list[3] and, therefore, covered by the more expansive cleanup and reporting requirements under that law.
In addition, EPA should list PFAS as a class and not just list PFOA and PFOS to ensure that states are notified of chemicals with similar structures and potentially similar hazards.
A wastewater discharge permit for a paper or textile mill is unlikely to have limits for PFASs, because the regulator would not be notified that the chemicals are present in the discharge.