Over the past year, the EPA has been tightening requirements around emerging contaminants like PFAS (per- and polyfluoroalkyl substances) and TCE (trichloroethylene). Even facilities that have traditionally generated only “non-hazardous” waste are starting to feel the ripple effects.
At Valicor, we often get questions from customers about what these rule changes mean for day-to-day operations and long-term planning. Below, we’ll walk through some of the most common ones we’re hearing right now.
Why is the EPA focused on PFAS and TCE?
PFAS and TCE have been under increasing scrutiny because of their health and environmental impacts. PFAS, often called “forever chemicals,” are extremely persistent in the environment and linked to health risks like cancer and immune system effects (EPA PFAS Roadmap). TCE is a solvent with well-documented risks, including developmental and neurological harm (EPA TCE Risk Evaluation).
Both substances are showing up in wastewater, sludges, and other byproducts, even when facilities don’t directly use them, because they’re common in supply chains and industrial inputs.
My facility only generates non-hazardous waste. Why should I be concerned?
That’s one of the biggest misconceptions. “Non-hazardous” doesn’t always mean “free of emerging contaminants.” A wastewater stream or residual might not be classified as hazardous under RCRA, but if it contains PFAS or TCE above certain thresholds, it may be subject to additional requirements.
The EPA recently issued an interim final rule adjusting compliance dates for TCE disposal in wastewater and solid waste systems (EPA compliance date update). This shows how quickly expectations can shift, even for facilities that aren’t used to thinking of themselves as handling “hazardous” material.
What’s changing with compliance timelines?
The EPA’s TCE rule extends some compliance deadlines into 2027, but facilities are still expected to prepare now for phasing out certain uses and ensuring safe disposal. Meanwhile, PFAS regulation is accelerating, with new drinking water standards finalized in 2024 and wastewater discharge guidelines under review.
The bottom line: timelines are moving targets. Facilities that profile their waste streams now (rather than waiting for final deadlines) are going to be in a stronger position to adapt.
How do these changes affect day-to-day operations?
The most immediate impact is around waste profiling and disposal choices. For example:
- Wastewater previously sent to a municipal treatment plant may need pretreatment or offsite processing if PFAS levels are too high.
- Sludges or residuals classified as “non-hazardous” might need additional handling steps if they contain TCE above EPA thresholds.
- Paperwork, recordkeeping, and sampling requirements are increasing in many states as regulators try to track PFAS sources.
Working with a waste provider like Valicor, you should have access to profiling services to help identify whether these substances are present in your waste streams. From there, we can recommend the best path forward, whether that’s centralized wastewater treatment, solidification, or a customized solution.
Are states doing their own thing, or is this just federal?
The short answer is: Both. While the EPA sets national baselines, states are moving ahead with their own rules. For instance, Michigan has been enforcing some of the most aggressive PFAS limits in wastewater and groundwater discharges for years (Michigan PFAS Action Response Team). Other states, like Maine and California, are exploring disposal restrictions that go beyond federal guidelines.
That means a facility operating in multiple states might face different compliance standards, even for the same waste streams. This patchwork adds complexity, but it also makes proactive waste profiling more valuable.
What can facilities do right now to prepare?
We recommend three practical steps:
- Get a clear waste profile. Sampling and analysis can confirm whether PFAS, TCE, or other priority contaminants are present.
- Review disposal pathways. Make sure wastewater, sludge, or off-spec product destruction is routed to facilities equipped to handle contaminants of concern.
- Build flexibility. Assume that compliance deadlines and thresholds may shift again. Having relationships with treatment providers and disposal partners now makes it easier to pivot later.
Valicor's centralized wastewater treatment facilities are designed to process complex, non-hazardous streams, including those with emerging contaminants. By treating water for reuse or safe discharge, we can help facilities stay ahead of shifting rules and maintain community trust.
Don't Lose Traction to Compliance
The conversation around PFAS and TCE isn’t slowing down. Even facilities that have never thought of themselves as “hazardous waste generators” are being pulled into the compliance landscape. By asking the right questions now and preparing waste streams for future standards, facilities can avoid costly surprises.
If you’d like to talk through how these changes may affect your operations, or how Valicor can help manage complex wastewater streams, we’d be glad to start that conversation.
