Each month Tim Stark introduces a new technical topic for discussion and possible action. This month’s topic is: “Update PFAS and PFOS Regulations & Compliance”. This topic generated significant discussion with the main “take-aways” being listed below:

PFAS Regulations

- No regulations promulgated yet so no compliance activities yet

- Proposed PFAS/PFOS rules released on 1/31/2024 – see excerpts below and full document at: prepublication_version_of_definition_of_hazardous_waste_proposal.pdf (epa.gov)

- Proposed rules released on 1/31/2024 do not classify PFAS/PFOS as a hazardous waste for disposal so they can be disposed in a Subtitle D facility (see pasted text below)

- See recent article on PFAS/PFOS regulations HERE.
- New drinking water standard lowers allowable level of PFAS/PFOS to 4 parts per trillion, which is hard to detect

- Kerry Rowe’s testing at Queens University shows many geomembranes exhibit good chemical resistance to PFAS/PFOS compounds (see FGI webinar that Kerry Rowe gave at this LINK.

- However, Kerry Rowe’s testing shows lower concentrations of PFOS exhibit higher diffusion rates than higher concentrations of PFAS through the geomembranes that he has tested

- Need long-term testing of geomembranes chemical resistance to PFAS/PFOS chemicals

- PFAS/PFOS somewhat new and predate geomembranes so PFAS/PFOS may be in prior chemical resistance testing that used actual leachate instead of synthetic leachate

- Some water agencies are asking if any geomembrane component is extractable PFAS/PFOS material over the service life of the geomembrane

- Manufacturers are being asked if PFAS/PFOS chemicals were used in geomembrane manufacturing? Manufacturers are reviewing their supply chain to confirm no traces of PFAS/PFOS due to requests of customers and regulators – manufacturers are issuing “to the best of our knowledge” letters about no PFAS/PFOS components

- National Sanitation Foundation (NSF) is pursuing extractable constituents and may include PFAS/PFOS – NSF 61

- NSF 61 is having training class in Michigan on April 24, 2024, which my address PFAS/PFOS

- Would be good to investigate water standards in Europe and Australia and how they are handling PFAS/PFOS

- Would be good to investigate municipal solid waste standards and compare them to water standards

- Military will be exempt from PFAS/PFOS regulations initially

- Any changes in geomembrane formulations to deal with PFAS/PFOS, none available yet

- Lots of litigation over PFAS/PFOS are underway

- Health impacts of PFAS/PFOS are starting to become understood

- No new placement restrictions at Subtitle D facilities for PFAS/PFOS compounds but a lot of Not In My Backyard (NIMBY) opinions because leachate will go to local treatment facility

- It is believed that PFAS/PFOS could have a large impact on waste and water industries

‍To see full document, please click on Download button below.