Thursday, April 20, 2023
9:00 AM - 9:45 AM (EDT)
Concurrent Session: PFAS In The Trash: The Hidden Impact Of EPA’s PFAS Actions On Solid Waste Management
Room A313 (GWCC)

EPA has launched significant PFAS actions in 2022 that are changing the solid waste management/recycling market. EPA proposed to add PFOA and PFOS as CERCLA hazardous substances. EPA also released its hazard assessments and found that these PFAS pose human health hazards below the limits of detection. While EPA’s CERCLA actions will eventually trigger clean up of certain PFAS releases at old landfills and waste discharge sites, CERCLA designation will have more far-ranging, immediate implications. Specifically, the law’s liability structure is strict, severable, and retroactive and will effectively make operators, towns, small businesses, and land trusts all liable as potentially responsible parties (PRPs). Towns that operate or contract for drinking water systems, sewage systems, and waste management and recycling services are largely unaware that PFOA and PFOS are found today in all these systems at levels 10 times greater than EPA’s “safe” levels, despite being phased out in 2005. To minimize CERCLA liability, towns will require solid waste operators to avoid accepting non-household wastes, screen recyclables for PFAS, and divert biosolids to secure landfills. These management changes will reduce waste service operators’ revenue and increase operating costs. In this presentation, we will demonstrate the magnitude of these cost impacts by using several towns as case studies of future market impacts.

Jonathan Gledhill
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