Connecticut Department of Energy & Environmental Protection

Identifying and Addressing Sources of PFAS Contamination

Minimizing Future Releases of PFAS to the Environment

A key recommended action of the Connecticut PFAS Action Plan is to minimize future release of PFAS to the environment. Strategies prioritized under this umbrella included 1) reducing and preventing future releases of PFAS-containing firefighting foam to the environment and 2) identifying and addressing other significant sources of PFAS contamination.

To address additional sources of significant PFAS contamination, the plan called for Connecticut agencies to identify operations and processes that may be sources of PFAS contamination; establish standards and discharge limits for PFAS in air and water; to evaluate the levels of PFAS that reach wastewater treatment plants; and to consider PFAS levels in biosolids and compost products.  DEEP, in partnership with other State agencies, has made significant progress towards these goals.

Identification of PFAS Operations and Processes
 PFAS in Firefighting Foams
 Permitting and Evaluation of PFAS in Wastewater and Sludge
    Municipal Wastewater Discharges
    Industrial Wastewater Discharges
    PFAS in Wastewater Sludge and Biosolids
Establishment of Air Emission Standards

Identification of PFAS Operations and Processes

The universe of industrial operations and processes that may potentially release PFAS to the environment is an active area of research.  DEEP is working closely with EPA and other state agencies to establish a common list of industries that use or generate PFAS during routine business operations. To do so, efforts are focused on evaluation of the PFAS potential of each North American Industry Classification System (NAICS) code. (When registering with the federal government, a business self-selects the NAICS code that best represents their primary activity type.)  Research has identified certain business activities, such as electroplaters and metal finishers, as more likely to be potential users or generators of PFAS. Establishing a list of standard industry codes that are most likely to use PFAS chemicals in their processes (either currently or historically), will assist the Agency with identifying those facilities most likely to pose a PFAS-risk to nearby environmental resources and the public. It's important to note that current or historic use of PFAS in a given industry type, does not necessarily mean that PFAS has been released to the environment by a particular facility within that industry type. (A property may be an administrative office building of a company that performs such industrial activities elsewhere, for example.)  DEEP will continue to update the public on its progress to finalize the PFAS industry code screening list.  

Additional Information

Addressing PFAS in Firefighting Foam

PFAS-containing aqueous film forming foams, also referred to as "AFFF" or "AF3", were historically used to respond to Class B flammable liquid and petroleum hydrocarbon fires.  These fluorinated foams are highly effective at extinguishing fires, but unfortunately contain large amounts of PFAS and can result in significant environmental contamination.  Areas of past AFFF release (e.g., former fire fighting training areas) are often characterized by extremely high levels of PFAS in soil and groundwater. 

Therefore, on July 13, 2021, the State of Connecticut enacted Public Act No. 21-191: An Act Concerning the Use of Perfluoroalkyl or Polyfluoroalkyl Substances in Class B Firefighting Foam.  The Act provided a phased-approach to eliminating the use of PFAS-containing firefighting foams in Connecticut.  The Act also called for DEEP and the Department of Emergency Services and Public Protection (DESPP) to collaborate with municipalities to conduct a 'take back' program of fluorinated firefighting foams.  In 2021 and 2022, the program collected more than 35,000 gallons of PFAS-containing firefighting foam concentrate from over 250 fire departments throughout Connecticut. The concentrate has been properly disposed of, eliminating the risk that these PFAS-containing materials might be released to the environment.  As part of the take-back program, DEEP and DESPP worked together to identify fluorine-free foam replacements and to evaluate decontamination methods for foam-containing fire apparatus. 

Visit the Reducing and Preventing Releases of PFAS-Containing Firefighting Foam webpage to learn more. 

Permitting and Evaluation of PFAS in Wastewater and Sludge

Municipal Wastewater Discharges 

Because of the widespread use of PFAS in household, commercial, and industrial products, PFAS are being detected in wastewater conveyed to wastewater treatment plants (also known as water pollution control facilities).  PFAS are not destroyed or removed at these plants and can be found in both the liquids and solids generated during the treatment process.  

In order to better understand PFAS concentrations currently entering and leaving municipal wastewater treatment plants, in 2021, DEEP hired a consultant to complete two rounds of PFAS sampling at thirty-five (about 40%) of the state’s publicly owned wastewater treatment plants (or publicly owned treatment works, POTWs). Samples of wastewater entering and discharging from each facility (i.e., influent and effluent), as well as sludge samples, were collected and analyzed for a target list of PFAS compounds. Samples of “scrubber water” (i.e., water used to treat smokestack emissions) was also collected from four of the five facilities that maintain sewage sludge incinerators. At ten sites, surface water upstream and downstream of the facility was collected as well as fish tissue samples. The information collected is being used by the Agency to inform future monitoring needs. 

Municipal wastewater discharges are regulated by the Municipal Wastewater Program within the DEEP Water Planning and Management Division.  At this time, PFAS monitoring is not required of municipal wastewater treatment facilities. However, once EPA finalizes analytical Method 1633, which will allow for uniform monitoring of PFAS in wastewater influent, effluent, and solids, the DEEP Municipal Wastewater program anticipates implementing a phased approach to integrate PFAS monitoring into wastewater treatment plant NPDES permits. Additional information will be shared as details of the phased approach are further developed. 

If you have questions about PFAS in municipal wastewater, please contact Stacy Pappano at stacy.pappano@ct.gov. 

Additional Resources:
Industrial Wastewater Discharges

EPA, in its effort to reduce PFAS discharges to waterways, issued a memo on December 5, 2022.  The memo recommends that states and municipalities use the most current sampling and analysis methods in their industrial wastewater permitting and pretreatment programs to identify known or suspected sources of PFAS and to take actions using their permitting authorities. 

In Connecticut, industrial wastewater discharges to municipal wastewater treatment facilities, surface waters and ground waters are overseen by the DEEP Water Permitting and Enforcement Division. Currently, the Division is at the investigatory stage of understanding PFAS data in industrial discharges in step with the region and national stage. The Division is requiring the collection of baseline PFAS monitoring data at industries with the potential for PFAS in their wastewater discharge.  Newly issued permits or registrations for these facilities will contain a special condition or compliance schedule requiring permittees to develop and implement a PFAS monitoring/sampling plan. Exact permit conditions will vary by facility, but generally are likely to include a requirement for two baseline sampling events by a qualified professional. Additional routine monitoring at a specified frequency and/or treatment requirements may be implemented on a case-by-case basis. 

In order to effectively tackle PFAS contamination in Connecticut, source reduction of PFAS is critical. DEEP is therefore working to incorporate PFAS screening requirements in industrial wastewater permit applications. Screening data will be utilized to help identify contributory sources of PFAS into municipal wastewater treatment facilities, , surface and ground waters. This information will be used to inform and develop future actions to mitigate PFAS contamination through monitoring, source reduction, and implementation of treatment technologies. 

To learn more, read the Water Permitting and Enforcement Division's PFAS Roadmap for Industrial NPDES and Pretreatment Permits. 

Additional Resources:

PFAS in Wastewater Sludge and Biosolids

In Connecticut, most of the sewage sludge generated at wastewater treatment plants is incinerated, and direct land application of wastewater sludge is not permitted. However, interstate commercial laws do allow for the sale of products made from wastewater sludge, such as pelletized biosolid-based fertilizers and soil amendments, to be sold within Connecticut. Unfortunately, many of these products contain PFAS and can result in soil and groundwater contamination.

As a result, in 2024, legislation was passed that bans the use, sale, or offering for sale as a soil amendment any biosolids or wastewater sludge that contains PFAS, effective October 1, 2024.  

Questions regarding this ban can be directed to the Sustainable Materials Policy and Planning Division within the DEEP Materials Management and Compliance Assurance Bureau by emailing Michael.Looney@ct.gov. 

Additional Resources: 

Establishment of Air Emission Standards

DEEP Air Bureau staff are closely monitoring the work of USEPA’s Office of Air and Radiation under the PFAS Strategic Road Map to develop the technical foundation to address PFAS air emissions. Our specific interest is in the creation of accepted methods to accurately quantify PFAS air emissions.  These are necessary to understand the fate and transport of PFAS and inform adequately protective federal and state PFAS air emissions standards. Additionally, Air Bureau Staff participate in regional and national workgroups to share learning and advocate for technical resources specific to PFAS air emission quantification and control techniques.   

Questions regarding the establishment of Connecticut PFAS air emission standards can be directed to Paul Farrell, Director of the Planning and Standards Division within the DEEP Bureau of Air Management, by emailing Paul.Farrell@ct.gov. 

Contact Information

Questions or comments regarding the environmental impacts of PFAS in Connecticut should be sent to DEEP.PFAS@ct.gov.

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Content last updated November 29, 2024.