PFAS

February 7, 2024

EPA alert

 

Proposed PFAS Hazardous Constituents Under RCRA

The Environmental Protection Agency (EPA) is proposing to amend its regulation under the Resource Conservation and Recovery Act (RCRA) by adding nine specific per-and polyfluoroalkyl substances (PFAS), their salts, and their structural isomers to its list of hazardous constituents. EPA’s criteria for listing substances as hazardous constituents under RCRA require that they have been shown in scientific studies to have toxic, carcinogenic, mutagenic, or teratogenic effects on humans or other life forms.

Entities potentially affected by this action include hazardous waste treatment, storage, and disposal facilities (TSDFs) with solid waste management units (SWMUs) that have released or could release any of the PFAS proposed to be listed as RCRA hazardous constituents. EPA has identified 1,740 such facilities, which could be subject to additional corrective action requirements (under RCRA section 3004(u) and (v)) to address releases not already subject to corrective action under EPA’s corrective action regulations.

The nine PFAS and common uses are as follows:

  1. Perfluorooctanoic acid (PFOA; CASRN 335-67-1). PFOA is an eight-carbon molecule with seven fully fluorinated carbon atoms, and one carboxylic acid functional group used as a processing aid to produce fluoropolymers found in cleaning agents, waxes, aqueous film-forming foam (AFFF), and other products.
  2. Perfluorooctanesulfonic acid (PFOS; CASRN 1763-23-1). PFOS is a fully fluorinated eight-carbon molecule with one sulfonic acid functional group used in AFFF surface treatments of textiles to provide oil and water resistance, metal plating, and other uses and industries.
  3. Perfluorobutanesulfonic acid (PFBS; CASRN 375-73-5). PFBS is a fully fluorinated four-carbon molecule with one sulfonic acid group. It has been used as a replacement for PFOS used in manufacturing paints and cleaning agents, metal plating, AFFF, to provide oil and water resistance, and other uses and industries.
  4. Hexafluoropropylene oxide-dimer acid (HFPO-DA or GenX; CASRN 13252-13-6). HFPODA is a six-carbon molecule consisting of five fully fluorinated carbon atoms, one ether functional group, and one carboxylic acid functional group. HFPO-DA is a chemical associated with GenX processing aid technology used to make fluoropolymers without PFOA.
  5. Perfluorononanoic acid (PFNA; CASRN 375-95-1). PFNA is a nine-carbon molecule with eight fully fluorinated carbon atoms and one carboxylic acid functional group. It has been used as a processing aid to produce fluoropolymers and has been used or found in metal plating, cleaning agents, waxes, AFFF, energetic materials, and other products.
  6. Perfluorohexanesulfonic acid (PFHxS; CASRN 355-46-4). PFHxS is a fully fluorinated six-carbon molecule with one sulfonic acid functional group used in AFFF surface treatments of textiles to provide oil and water resistance, in metal plating, and in other uses and industries.
  7. Perfluorodecanoic acid (PFDA; CASRN 335-76-2). PFDA is a ten-carbon molecule with nine fully fluorinated carbon atoms and a carboxylic acid functional group. It has been used as a processing aid to produce fluoropolymers and has been used or found in metal plating solutions, cleaning agents, waxes, AFFF, and other products.
  8. Perfluorohexanoic acid (PFHxA; CASRN 307-24-4). PFHxA is a six-carbon molecule with five fully fluorinated carbon atoms and a carboxylic acid functional group. It has been used or found in metal plating solutions, cleaning agents, waxes, AFFF, and other products.
  9. Perfluorobutanoic acid (PFBA; CASRN 375-22-4). PFBA is a four-carbon molecule with three fully fluorinated carbon atoms and one carboxylic acid functional group. It has been used or found in metal plating, cleaning agents, waxes, AFFF, energetic materials, and other products.

 

EPA will collect comments on this PFAS to RCRA’s hazardous constituents proposal for 60 days once published in the Federal Register. Read a prepublication copy of this proposal.

Submit your comments on the Federal eRulemaking Portal: https://www.regulations.gov and identified by Docket ID No. EPA-HQ-OLEM-2023-0278.

 

As a result of this proposed rule, if finalized, when imposing corrective action requirements at a facility, these PFAS would be among the hazardous constituents expressly identified for consideration in RCRA facility assessments and, where necessary, further investigation and cleanup through the RCRA corrective action process at RCRA treatment, storage, and disposal facilities. Contact SCS Engineers for guidance about your facility at .

 

Additional Resources:

For additional information regarding EPA’s proposed RCRA PFAS rules, see:

 

 

 

Posted by Diane Samuels at 12:52 pm

January 11, 2024

Join SCS Engineers stormwater professionals, including our National Stormwater Expert, Jonathan Meronek,  at StormCon 2024, August 27-29 at the Grand Sierra Resort and Casino in Reno, NV.

Jonathan Meronek
Jonathan J. Meronek, QISP-ToR, ENV SP, CPESC, QSP/D, SCS Engineers National Stormwater Expert

StormCon 2024 is the stormwater industry’s premier event connecting stormwater and surface water managers, erosion control specialists, and engineers from around North America for idea-sharing, information exchange, and networking. Featuring a multi-track conference program led by top leaders in the industry, StormCon 2024 provides exceptional opportunities to learn, engage and build key contacts.  Topics this year may include:

  • Industrial Stormwater Management
  • Green Infrastructure
  • Flood Modeling & Mitigation
  • Programs, Permits and Compliance
  • Transportation & Construction Stormwater
  • BMP Monitoring
  • PFAS

The StormCon 2024 conference provides plenty of networking opportunities, certification courses, and an exhibit hall.

Click for more conference details and registration information.

 

 

Posted by Laura Dorn at 10:27 am

August 17, 2023

Meet SCS Engineers professionals at the Iowa Society of Solid Waste Operations (ISOSWO)’s Recycling & Solid Waste Management Fall Conference, October 2-4, at the Waterloo Convention Center in Waterloo, Iowa.

The conference will feature networking opportunities, a solid waste tour and a sustainability walking tour, exhibits, and auction, and educational sessions.

Click for more details and registration information

 

Posted by Laura Dorn at 3:15 pm

August 15, 2023

PFAS CERCLA Exemption

 

PFAS CERCLA Exemption Letter Submitted Electronically to: https://www.regulations.gov
The Honorable Michael Regan, Administrator U.S. Environmental Protection Agency

Re: Addressing Per- and Polyfluoroalkyl Substances in the Environment, Advance Notice of Potential Rulemaking (ANPRM); Docket ID No. EPA-HQ-OLEM-2022-0922

Last year, NWRA and SWANA submitted comments on EPA’s proposal to designate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as CERCLA hazardous substances. They also submitted comments in May in response to this ANPRM jointly with other “passive receivers” of per- and polyfluoroalkyl substances (PFAS). Both associations reiterate and append those comments to what is contained in this letter, urging EPA to ensure that landfills and other passive receivers are afforded relief from CERCLA contribution litigation prior to designating PFAS as hazardous substances.

 

READ THE PFAS CERCLA LETTER

 

More Information:

 

 

 

Posted by Diane Samuels at 8:48 am

July 18, 2023

Meet SCS Engineers Environmental Professionals at the AEHS Foundation’s 39th Annual Conference on Soils, Sediments, Water, and Energy, October 16-19, in Amherst, Massachusetts.  

This is AEHS’s “East Coast” environmental conference, and it brings together some 600-800 participants with diverse backgrounds, including representatives from state and federal agencies, environmental engineering firms, consulting companies, industry leaders, and esteemed academia — truly a gathering of the best and brightest minds in the field.

The conference delivers a robust and varied technical program with presentations on cutting-edge research, innovative approaches, and practical insights.  The conference offers participants the opportunity to be part of a vibrant community dedicated to developing creative, cost-effective assessments and solutions to meet regulatory demands, shape a sustainable future, and make a lasting impact in the environmental field.

The Association for Environmental Health and Sciences Foundation, Inc. (AEHS) is a non-profit, member-supported, professional organization, with the purpose of facilitating communication and fostering cooperation among professionals concerned with the challenge of soil, sediment, and water assessment, cleanup, and protection.

We hope to see you there!  For more conference details and registration information, click here

 

 

Posted by Laura Dorn at 11:36 am

May 15, 2023

Join SCS Engineers professionals at the IEA’s 39th Annual Environmental Training Symposium & Conference, June 1-2, at the San Diego Convention Center.

This conference includes over two dozen educational sessions on four tracks running simultaneously over two days, and features a robust Exhibit Hall, an Awards Luncheon, and a San Diego Bay Yacht Cruise. Panels topics will include air, hazardous materials, health & safety, sustainability, and water quality, with expert speakers from Southern California.

Hundreds of attendees from various professions such as environmental, health, and safety experts, NGO representatives, environmental engineers from public and private sectors, environmental consultants and attorneys, government affairs representatives, DoD, and many more are expected to attend.

Click for more details and registration information.  Hope to see you there!

 

 

Posted by Laura Dorn at 6:02 pm

April 11, 2023

SCS Engineers is hosting our 2023 Pennsylvnia Solid Waste Seminars on Tuesday, June 6 in Harrisburg, PA.

This half-day seminar is designed to provide updates on the latest regulatory, policy, and technological developments in the solid waste, landfill, landfill gas, and sustainable materials management industries.  The sessions are presented by experienced SCS professionals, and continuing education units are available.

This year, our professionals will cover these important topics:

  • Use of Geographic Information Systems (GIS) for Landfill Gas Data Analysis and OM&M, by Justin Stevenson
  • Leachate PFAS Treatment, by Sam Cooke
  • Compost Best Management Practices, by Greg McCarron
  • Emerging LFGE Financial Drivers: eRINs, Crypto, and Funding from the Fed, by Eric Peterson
  • Indicators of Heat Generation Processes that May Cause Elevated Temperature Landfills, by David George
  • Tools to Estimate GHG Emissions from Landfills, by Lisa Wilkinson
  • Pennsylvania Regulatory Update, by Josh Roth

Lunch will be provided, followed by Disc Golf.

The seminar is intended for solid waste management professionals, landfill managers, waste/recycling managers, supervisors, and operators. For attendees already possessing solid waste management and disposal experience, topics will provide a fresh perspective and cover important regulatory and technological updates. For those new to the field, topics will cover essential information on various critical aspects of waste/ recycling program collections, transfer, processing, and disposal, as well as landfill development, operations, monitoring, and management

We look forward to seeing you there!

 

Posted by Laura Dorn at 3:31 pm

March 14, 2023

Visit SCS Engineers professionals at BOOTH 60 at the 2023 Louisiana Environmental Conference and Trade Fair, March 15-17, at the Cajundome & Convention Center in Lafayette, Louisiana.

The conference will feature many presentations and opportunities to learn from industry experts, as well as several networking opportunities including a golf outing, opening reception, and crawfish boil and fish fry.

The conference is hosted by the Louisiana Solid Waste Association.

Click for more information

 

Posted by Laura Dorn at 10:14 am

March 9, 2023

Hear from SCS Engineers experts at the ninth Global Waste Management Symposium in Indian Wells, California, February 25-28, 2024.  SCS is also is a Silver Sponsor of the conference.

The GWMS serves as a forum to discuss applied and fundamental research, case studies and policy analysis on solid waste and materials management. The community of researchers, engineers, designers, academicians, students, facility owners and operators, regulators and policymakers will participate.

Numerous SCS Engineers experts will be on hand to discuss your solid waste management challenges, and several are presenting at the symposium, including:

Alex Stege is discussing “LFG Recovery Forecasting Uncertainty and the Effects of Organics Diversion”
[Monday, February 26, Track A, 10:30 am – Noon]

Kelli Farmer will present “From Drilling to Digesting: An Anaerobic Digestion Feasibility Study”
[Monday, February 26, Track A, 10:30 am – Noon]

Ray Huff is providing “An Update on the WAG: Case Studies on Recent Innovations in Landfill Gas Data Analysis”
[Monday, February 26, Track A, 2:00-3:30 pm]

Vita Quinn is discussing “Creating a Sustainable Approach to Waste Management”
[Monday, February 26, Track C, 2:00-3:30 pm]

The Environmental Research & Education Foundation (EREF) is a strategic partner of the symposium.

Click here for schedule, registration, and other conference details

 

Hope to see you there!

 

 

 

Posted by Laura Dorn at 11:06 am

February 17, 2023

EPA grant funding

On February 13, 2023, the EPA announced the availability of $2 billion of grant funding to address emerging contaminants, like Per- and Polyfluoroalkyl Substances (PFAS) in drinking water across the country. This investment, which is allocated to states and territories, will be made available to communities as grants through EPA’s Emerging Contaminants in Small or Disadvantaged Communities (EC-SDC) Grant Program and will promote access to safe and clean water in small, rural, and disadvantaged communities while supporting local economies.

This initial allotment of $2 billion to states and territories can be used to prioritize infrastructure and source water treatment for pollutants, like PFAS and other emerging contaminants, and to conduct water quality testing. EPA awards funding to states based on an allocation formula that includes factors such as population, number of water systems, and data related to emerging contaminants. EPA’s implementation documents contain information on how EPA will award and administer the EC-SDC grants. Participating states and territories should submit application packages for the grant funding at https://www.grants.gov.

 

Additional Resources:

 

 

Posted by Diane Samuels at 6:00 am
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