The 79th Annual Conference is one of the Midwest’s largest gatherings of safety and health professionals. It is the perfect opportunity for decision-makers to find new products and services, and learn more about the environmental concerns they are facing. SCS Engineers’ Cheryl Moran is attending; she looks forward to meeting and greeting you soon! Cheryl is ready to share her industry expertise with colleagues and peers on safety.
Half-day sessions starting at 8:00 am on Tuesday, April 20, 2021 – Thursday, April 22, 2021
Wednesday at 10:00 AM join us at Session #17 PFAs – An Update On This Emerging Contaminant
Tony Kollasch, Project Manager, and Jeff Marshall, Vice President, National Expert on Innovative Technologies, SCS Engineers discuss the history of PFAs, why people are concerned about PFAs, the current state of environmental
regulations regarding this substance, and the likely future of PFAs concerns.
Comment on EPA’s Draft Interim Guidance on PFAS Destruction and Disposal – Deadline February 22
February 9, 2021
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.
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:
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
US Composting Council Virtual Compost 2021 Conference and Tradeshow
January 26, 2021
Join the US Composting Council for its Virtual Compost 2021 conference and tradeshow, January 26 & 27, 2021.
With three focused tracks (operations; collection, policy, research; and product quality, use and markets) and 20+ speakers over two days, Virtual COMPOST2021 will be the go-to compost event of the year. Conference topics include:
EPA’s PFAS Interim Strategy for Certain EPA-Issued Wastewater Permits
December 23, 2020
On November 30, 2020, the Environmental Protection Agency announced it is aggressively addressing per- and polyfluoroalkyl substances (PFAS) in the environment. The agency announced two steps that it states would help ensure that federally enforceable wastewater monitoring for PFAS can begin as soon as validated analytical methods are finalized.
First, EPA issued a memorandum detailing an interim National Pollutant Discharge Elimination System (NPDES) permitting strategy for addressing PFAS in EPA-issued wastewater permits.
EPA’s interim NPDES permitting strategy for PFAS advises EPA permit writers to consider including PFAS monitoring at facilities where these chemicals are expected to be present in wastewater discharges, including from municipal separate storm sewer systems and industrial stormwater permits. The PFAS that could be considered for monitoring will have validated EPA analytical methods for wastewater testing. The agency anticipates being available on a phased-in schedule as multi-lab validated wastewater analytical methods are finalized. The agency’s interim strategy encourages the use of best management practices where appropriate to control or abate the discharge of PFAS and includes recommendations to facilitate information sharing to foster adoption of best practices across states and localities.
Second, EPA released information on progress in developing new analytical methods to test for PFAS compounds in wastewater and other environmental media.
In coordination with the interim NPDES permitting strategy, EPA is developing analytical methods in collaboration with the U.S. Department of Defense to test for PFAS in wastewater and other environmental media, such as soils. The agency is releasing a list of 40 PFAS chemicals that are the subject of analytical method development. This method would be in addition to Method 533 and Method 537.1 that are already approved and can measure 29 PFAS chemicals in drinking water. EPA anticipates that multi-lab validated testing for PFAS will be finalized in 2021. For more information on testing method validation, see https://www.epa.gov/cwa-methods.
EPA continues to expand its PFAS Action Plan to protect the environment and human health. To date, it has assisted more than 30 states in helping address PFAS, and the agency is continuing to build on this support. Across the nation, the EPA has addressed PFAS using a variety of enforcement tools under SDWA, TSCA, RCRA, and CERCLA (where appropriate), and will continue to protect public health and the environment.
The agency is also validating analytical methods for surface water, groundwater, wastewater, soils, sediments, and biosolids; developing new methods to test for PFAS in air and emissions; and improving laboratory methods to discover unknown PFAS. EPA is developing exposure models to understand how PFAS moves through the environment to impact people and ecosystems.
EPA published a validated method to test for and measure 29 chemicals in drinking water accurately.
EPA implemented the agency’s PFAS Action Plan by proposing to regulate PFOA and PFOS drinking water, asked for information and data on other PFAS substances, and sought comment on potential monitoring requirements and regulatory approaches. The EPA anticipates proposing nationwide drinking water monitoring for PFAS that uses new methods to detect PFAS at lower concentrations than previously possible.
This blog references information issued from the US EPA, Office of Public Engagement.
Posted by Diane Samuels at 6:00 am
PFAS – the financial and logistical challenges for landfills
December 2, 2020
Across the industry, stakeholders agree the next few years will be critical in shaping how landfills deal with PFAS and how the public perceives it. Waste trade associations, scientists, and a host of organizations are in the midst of conducting a number of studies looking closely at the issue, PFAS treatment options, the positive impact of recycling, and regulatory policies.
While there are sites noted in the article, there’s no practical way for most companies and landfills to respond at this time responsibly. Additionally, landfills are unique; no two are alike. Most human exposure to PFAS occurs through contaminated food. The majority of landfill leachate is pre-treated at the landfill before going to a wastewater treatment plant, where additional treatment occurs before discharge.
According to EREF President Dr. Bryan Staley, in the article, “The relative impact of leachate as a human exposure pathway needs further evaluation to understand its relative degree of importance as it relates to health implications.”
Dr. Gomathy Radhakrishna Iyer, landfill leachate and design expert for SCS Engineers, said some operators are waiting to see what regulations may come even as they work on accounting for potential compliance issues and seeking solutions. “When the clients are thinking of upgrading their treatment plans, some are definitely taking into consideration PFAS treatment,” Radhakrishna Iyer said.
“You’re spending millions of dollars, you need to do your due diligence, right? At this point, consideration should be given to PFAS treatment during the feasibility stages,” she said.
Meet SCS Professionals, including Christine Stokes – Project Manager in our Suffern, NY, office, at NEWMOA’s Science of PFAS Conference: Public Health & The Environment, at the Sheraton Hotel and Conference Center in Framingham, MA, December 1 and 2.
The conference will also feature poster sessions, exhibits, and plenty of networking opportunities.
The conference is hosted by the Northeast Waste Management Officials’ Association (NEWMOA), a non-profit, non-partisan interstate association composed of state environment agency programs that address pollution prevention, toxics use reduction, sustainability, materials management, hazardous waste, solid waste, emergency response, waste site cleanup, underground storage tanks, and related environmental challenges in the northeast states.
The Recycling Association of Minnesota, the Minnesota chapter of the Solid Waste Association of North America, and the Minnesota Solid Waste Administrator’s Association teamed up to host a series of 10 webinars running every Thursday from September 10th through November 12th.
The webinars will cover such topics as
Solid Waste Management Industry Resilience
The State of Recycling and Solid Waste in Minnesota from the MPCA
Direction of the Solid Waste and Recycling Industry
Recycling and Disposal of Green Energy Components
Expanding End Markets for Problem Plastics
Recycled Feedstock for Essential Manufacturing During COVID-19
Complementing the Interstate Technology and Regulatory Council’s – ITRC, PFAS Technical and Regulatory Guidance, the website now has ITRC Per- and Polyfluoroalkyl Substances – PFAS, and Risk Communication Fact Sheets available. The site and updated content replace older fact sheets with more detailed information and useful for those who wish to understand the discovery and manufacturing of PFAS, information about emerging health and environmental concerns, and PFAS releases to the environment with naming conventions and federal and state regulatory programs.
SCS Engineers’ professionals recommend further reading to understand specific chemicals or subgroups of chemicals under study to comprehend PFAA behavior in the environment. There are appropriate tools to develop a site-specific sampling and analysis program and considerations for site characterizations following a PFAS release.
Firefighting Foams – Aqueous film-forming foam (AFFF) users and those who manage AFFF releases.
The Interstate Technology and Regulatory Council (ITRC) is a state-led coalition working to reduce barriers to the use of innovative air, water, waste, and remediation environmental technologies and processes. ITRC documents and training can support quality regulatory decision making while protecting human health and the environment. ITRC has public and private sector members from all 50 states and the District of Columbia and is a program of the Environmental Research Institute of the States (ERIS), a 501(c)(3) organization incorporated in the District of Columbia and managed by the Environmental Council of the States (ECOS).
National paradigm shifts for using new technology
Harmonized approaches to using innovative technology across the nation
Increased regulatory consistency for similar cleanup problems in different states
Reduce the review and permitting times for innovative and proven approaches to environmental prevention and mitigation programs
provides Prevention with Risk Management, Process Safety, and Spill Prevention Plans
Can help reduce the possible impact on environmental insurance
Faster cleanup with less environmental impacts
Decrease compliance costs
Provides technical and regulatory expertise for public outreach
Regularly engages with state and federal regulators and compliance enforcement as a trusted engineering firm.
Posted by Diane Samuels at 6:00 am
Real Estate Development – New PFAS Policies Impact Environmental Due Diligence
August 27, 2020
Perfluoroalkyl and polyfluroalkyl substances (PFAS) and other emerging contaminants are becoming increasingly important for real estate transactions. Several states have adopted or proposed health guidelines or Maximum Contaminant Levels (MCLs) for PFAS in their state. States with adopted limits include CA, CT, CO, MN, NC, NH, NJ, and VT; and states with proposed limits include IL, MA, MI, and NY. You can track bills by state here.
The Wisconsin Department of Natural Resources (WDNR) and the Environmental Protection Agency (EPA) are focusing their attention on these contaminants. The WDNR recently issued letters to more than 3,000 responsible parties listed with open cases on the DNR’s Bureau for Remediation and Redevelopment Tracking System (BRRTS) requesting they review PFAS use at open sites. Read a sample of the DNR letter.
With WDNR’s increasing focus on PFAS, a lack of sufficient due diligence, which includes evaluations for PFAS, could lead to significant additional liability for property purchasers, developers, and lenders. In addition, a lack of sufficient assessment could lead to a delay in case closure even after responsible parties have addressed all other contaminants and potential exposure pathways at a site. A sufficient assessment for PFAS will depend on site-specific factors and should carefully consider the associated risks and liabilities.
For real estate buyers, owners, developers, lenders, brokers, and contractors the potential presence of PFAS at a property presents significant liabilities that need to be incorporated into due diligence procedures and safe work plans. The investigation and remediation of sites with PFAS contamination can be expensive, and the WDNR is working to define enforceable cleanup goals for soil and groundwater.
PFAS are often referred to as “forever chemicals” due to their inability to be broken down in the environment. Due to the very high toxicity of PFAS, the proposed groundwater standard is extremely low – in the parts per trillion, which is more than 100 times lower than the groundwater standards for other well-known toxic contaminants such as benzene from gasoline or tetrachloroethylene commonly used at dry cleaners and industrial facilities.
PFAS are found in a wide variety of products, including nonstick coatings (e.g., Teflon), water-repellent coatings used on clothing and food packaging, fume suppressants, and firefighting foams. Potential sources of PFAS include many types of manufacturing and processing facilities, locations where firefighting foams have been used, metal plating facilities, wastewater treatment plants, and many more.
PFAS systems can treat and clean sources and remediation solutions by environmental engineers can bring properties back to life; safe to build and live on.
Posted by Diane Samuels at 6:00 am
How do you like your cheeseburger? Lettuce, tomato, hold the PFAS
August 17, 2020
Chemical companies are phasing out certain PFAS commonly used in fast food wrappers – read the full story and report at C&EN.
Chemical manufacturers are planning to gradually ramp down sales of certain short-chain per- and polyfluoroalkyl substances (PFAS) used as grease-proofing agents on fast food wrappers, take-out containers, and other paper-based food packaging, the US Food and Drug Administration announced July 31.
AGC Chemicals Americas, Archroma Management, and Daikin America will phase out sales of substances that contain 6:2 fluorotelomer alcohol (6:2 FTOH) for use in paper and cardboard food packaging beginning in January 2021. The process is expected to take 3 years, with up to an additional 18 months to use up existing stocks. A fourth company, Chemours, told the FDA last year that it has already stopped selling the substances in the US market.
PFAS that contain 6:2 FTOH replaced long-chain PFAS in food packaging nearly a decade ago because of concerns about the safety of long-chain PFAS, which are linked to cancer and immune disorders. FDA scientists, however, are now questioning the safety of those replacements. Data from rodent studies suggest that 6:2 FTOH accumulates in the body, the FDA reported in January (Toxicol. Appl. Pharmacol. 2020, DOI: 10.1016/j.taap.2020.114878).
“The data suggest the potential of 6:2 FTOH to also persist in humans from chronic dietary exposure,” the FDA says in a statement. “Further scientific studies are needed to better understand the potential human health risks from dietary exposure to food-contact substances that contain 6:2 FTOH.”
Rather than conduct those tests, the three manufacturers of the substances in question agreed to phase out sales in the US. – read the full story and report at C&EN.