On July 1, EPA released draft guidance on reducing risk from perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) in biosolids. The guidance aims to help water and wastewater utilities, landowners, state agencies, and the public reduce risk from PFOA and PFOS in biosolids. According to the Federal Register notice, the intent of the draft guidance memorandum is to provide non-binding or voluntary recommendations for water systems and other parties on how to mitigate risks from PFOA and PFOS in sewage sludge. EPA states that the guidance does not establish new regulatory requirements or supersede existing federal, state, or local requirements.
The draft guidance summarizes current management practices, includes a recap of numerous state approaches to biosolids management, and provides recommendations for land applications, public use of biosolids products, and wastewater treatment plant operations. The draft guidance also includes recommended strategies for reducing PFAS loading into wastewater treatment plants, including source identification, industrial pretreatment, monitoring, and pollution prevention. The document also provides an overview of options for using, disposing, or destroying PFAS-containing biosolids, including land application, surface disposal, and incineration. Finally, the document includes potential federal funding programs that may support PFAS-related management efforts.
The Association previously provided feedback to the Agency on its Draft Sewage Sludge Risk Assessment for PFOA, PFOS, which reflected the Agency’s estimation of the potential risks to human health posed by PFOA and PFOS in biosolids that are applied on land, disposed in a landfill, or incinerated. The comments urged the Agency to amend and revisit its methodological gaps in the risk assessment before finalizing publication. The comments expressed concern about the assessment’s use of unrealistic exposure assumptions, limited use of exposure routes, and lack of contextual comparison to other PFOA and PFOS sources.
AMWA will work with the regulatory subcommittee to develop comments in response to the draft guidance. Comments on the draft guidance are due to EPA on September 4.