Comment on EPA’s Draft Interim Guidance on PFAS Destruction and Disposal – Deadline February 22

February 9, 2021

SCS Engiineers provides regulatory updates for industrial clients

EPA is releasing the interim guidance for public comment. The guidance provides information on technologies that may be feasible and appropriate for the destruction or disposal of PFAS and PFAS-containing materials. It also identifies needed and ongoing research and development activities related to destruction and disposal technologies, which may inform future guidance.

The interim guidance addresses PFAS and PFAS-containing materials including:

  • Landfill leachate containing PFAS.
  • Soil and biosolids.
  • Solid, liquid, or gas waste streams containing PFAS from facilities manufacturing or using PFAS.
  • Textiles, other than consumer goods, treated with PFAS.
  • Spent filters, membranes, resins, granular carbon, and other waste from water treatment.
  • Aqueous film-forming foam (for firefighting).
  • The interim guidance is not intended to address the destruction and disposal of PFAS-containing consumer products, such as non-stick cookware and water-resistant clothing.

The agency is also providing guidance on testing and monitoring air, effluent, and soil for releases near potential destruction or disposal sites. EPA’s interim guidance captures the significant information gaps associated with PFAS testing and monitoring and identifies specific research needs.

The interim guidance is intended to assemble and consolidate information in a single document that generally describes thermal treatment, landfill, and underground injection technologies that may be effective in the destruction or disposal of PFAS and PFAS-containing materials.

As further research and development occur on this issue, EPA will incorporate this increased knowledge into future versions of this guidance to help decision-makers choose the most appropriate PFAS disposal options for their particular circumstances. EPA will review and revise the interim guidance, as appropriate, or at least once every 3 years.

See the EPA website: EPA Interim Guidance on Destruction and Disposal of PFAS.

Comments must be received on or February 22, 2021.

Instructions: All submissions received must include Docket ID No EPA-HQ-OLEM-2020-0527 for this rulemaking. Comments received may be posted without change to the Federal eRulemaking Portal. You may send comments by any of the following methods:

  • Federal eRulemaking Portal: https://www.regulations.gov/ (EPA’s preferred method). Follow the online instructions for submitting comments.
  • Agency website: www.epa.gov/pfas. Follow the online instructions for submitting comments.
  • Mail: U.S. Environmental Protection Agency, EPA Docket Center, OLEM Docket, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
  • Hand Delivery/Courier: EPA Docket Center, WJC West Building, Room 3334, 1301 Constitution Avenue NW, Washington, DC 20004. Open 8:30 a.m.-4:30 p.m. ET, Monday-Friday.
  • Comment to NWRA and SWANA (see below).

 

Industry Comments on EPA’s PFAS Draft Interim Guidance

 

According to Waste Dive, the document is the first such federal guidance on the destruction or disposal of PFAS or PFAS-containing materials. It describes the available science used in three major techniques: deep well injection, landfilling and thermal treatment. Acknowledging uncertainty about potential environmental effects, the EPA proposed the interim storage of PFAS-containing waste until further research can “reduce the uncertainties associated with other options.”

Industry groups such as the National Waste & Recycling Association (NWRA) and the Solid Waste Association of North America (SWANA) said they are analyzing the document and discussing with their members, such as SCS Engineers what the interim guidance means for daily landfill operations. The trade groups will submit comments on the document by the Feb. 22 deadline.

 

 

 

Posted by Diane Samuels at 6:00 am