ASDWA Submits Comments on EPA’s Interim PFAS Destruction and Disposal Guidance

On February 22, ASDWA submitted comments on EPA’s “Interim PFAS Destruction and Disposal Guidance.” ASDWA’s comments highlight that destruction and disposal of PFAS is a significant concern for state drinking water programs and drinking water utilities that have to install expensive treatment to remove PFAS from drinking water sources contaminated by the manufacture, use, and disposal of PFAS and PFAS-containing materials through air deposition, landfill leachate, industrial wastewater streams, wastewater treatment facilities, and groundwater discharges. Key points from the comments include ASDWA recommendations for EPA to:

  • Undertake a holistic lifecycle approach using all federal authorities to assess, address, and remove or prevent PFAS from entering the environment (and drinking water sources) from all contributing media.
  • Provide additional guidance for drinking water treatment disposal and destruction technologies that are safe, easily implemented, and affordable.
  • Ensure public health protection considerations for vulnerable populations by providing more information and clearly explaining how all PFAS exposure pathways fit together, how they impact the other, and how they impact drinking water sources.
  • Directly engage with state drinking water programs, drinking water utilities and other important stakeholders to ensure the complete consideration of PFAS destruction and disposal impacts for all media.

ASDWA’s comments also note appreciation for the extent of information provided in the interim guidance, the acknowledgement of limitations in current research and data, and EPA’s continuing research to better characterize, measure, assess effectiveness and costs, improve and/or develop new methods for PFAS disposal and incineration, and develop PFAS monitoring methods for air, effluent, and soil releases. For more information, visit EPA’s website and read ASDWA’s comments here.