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On July 1, 2026, Virginia’s expanded PFAS monitoring requirements took effect. Under the state’s 2026 legislation (SB 138 / HB 938), specified industrial users that discharge to publicly owned treatment works (POTWs) must now conduct quarterly PFAS discharge monitoring and report the results to their POTW. Every affected facility is now part of a data set its local authority didn’t previously have to collect — and that record will matter when permit renewals come around.
Virginia isn’t an outlier. It’s a preview. Understanding what PFAS in industrial wastewater means for your permit is quickly becoming part of the EHS director’s job, whether or not your state has acted yet.
EHS directors who aren’t already thinking about their PFAS discharge profile are going to find themselves characterizing it under pressure instead of on their own timeline. The facilities that handle this well get ahead of it.
PFAS — per- and polyfluoroalkyl substances — are a class of thousands of synthetic compounds built around extremely strong carbon-fluorine bonds that resist heat, water, oil, and biological breakdown. That persistence is exactly why they show up in industrial wastewater: once PFAS enter a discharge stream, conventional treatment doesn’t remove them, so they pass through and accumulate downstream.
PFAS are used across a wide range of industrial processes — surface coatings, surfactants, fluoropolymer production, and legacy AFFF firefighting foams among them. Your facility may use or generate certain PFAS compounds depending on your process chemistry, sometimes through raw materials you wouldn’t immediately flag: lubricants, cleaning agents, packaging, and treatment additives can all carry them. The question isn’t whether PFAS regulation affects your industry in general. It’s whether you know what’s in your discharge specifically.
An expanding set of states now require some form of PFAS monitoring for industrial dischargers. Virginia’s 2026 requirements took effect July 1, 2026, directing specified industrial users that discharge to POTWs to perform quarterly PFAS monitoring over an initial one-year characterization period and report results to their POTW, which in turn reports to the state. States including North Carolina, Michigan, and Colorado have used discharge-permit authority to require PFAS monitoring or limits as well.
The mechanism matters more than the map. Once a POTW is required to trace PFAS back to its industrial sources, the facilities discharging into that system become the next question — regardless of whether a rule names them directly. You can read Virginia’s implementation details on the Virginia DEQ Industrial User PFAS Monitoring page.
EPA’s effluent guidelines agenda is moving PFAS from a monitoring question toward a permit-limit question. The agency has PFAS effluent limitations under development for sectors including PFAS manufacturers and metal-finishing operations, with additional sectors under review. For most facilities, though, the near-term risk isn’t a federal effluent limit landing on the permit tomorrow.
The immediate risk is the next permit renewal — when a POTW, now required to monitor, starts asking its significant industrial users what they’re contributing. Facilities running digital remote monitoring on conventional parameters often have no equivalent visibility into their PFAS profile. That gap is what regulators find first.
In facilities we work with, wastewater characterization gaps surface during permit renewals, not routine inspections. By the time the question is on the table, you’re under a timeline you didn’t set. The facilities that manage this well characterized their discharge before anyone required them to — not because they had to, but because they had a program that told them what was actually in their water.
Send us a sample. We'll characterize your wastewater — including a PFAS scan by EPA Method 1633 — so you're answering your permitting authority with data, not guesses.
Request a wastewater sample test →Virginia’s rule names specific categories of industrial users, and they map closely to the sectors EPA is scrutinizing nationally. If your facility falls into one of these, assume PFAS characterization is coming:
Any facility using fluorine-based chemistry or surfactants should assess its discharge profile, even without a rule naming it yet.
The regulatory picture is moving on two tracks at once — state monitoring rules and federal effluent limits. Here’s the current landscape:
| Jurisdiction / Action | Status | What It Requires |
|---|---|---|
| Virginia — SB 138 / HB 938 (industrial users to POTWs) | Effective July 1, 2026 | Quarterly PFAS monitoring via EPA Method 1633; one-year initial characterization; results reported to the POTW. |
| Virginia — Water Control Board VPDES regulation | In rulemaking (2026) | Incorporates PFAS monitoring for POTWs and industrial users into state pretreatment regulations. |
| EPA — effluent limits, PFAS manufacturers | Under development | Proposed effluent limitations guidelines for facilities manufacturing PFAS. |
| EPA — effluent limits, metal finishing / electroplating | Under development | Effluent limits targeting PFAS discharge from chromium electroplating and metal finishing. |
| Other states (NC, MI, CO, and expanding) | Active | PFAS monitoring or discharge limits imposed through state discharge-permit authority. |
Getting ahead of PFAS is a four-step process you can start before any deadline forces it:
That baseline does two things. It tells you whether you have a material issue to manage. And it gives you a defensible position in any future conversation with your permitting authority or a POTW now required to trace industrial contributors. Facilities that can produce a discharge characterization with dates, methods, and results when asked are in a fundamentally different position than those responding under pressure. For related discharge-compliance context, see our breakdown of wastewater surcharges and BOD/TSS.
The straightforward first move is baseline testing — before any regulatory deadline forces the question. If your process chemistry involves compounds in the PFAS family, understand which ones and at what concentrations while it’s still your decision to make.
The window to act proactively is closing faster than most EHS directors realize.
Request your wastewater sample test. We'll run a PFAS scan by EPA Method 1633 and give you a discharge profile with dates, methods, and results you can put on the table.
Request your wastewater sample test →One characterization by EPA Method 1633 tells you what’s in your discharge — before your POTW or permitting authority asks.
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See wastewater sample testing →Digital remote monitoring tracks your conventional discharge parameters continuously, so nothing drifts unseen between characterizations.
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