Impact of PFAS on Biosolids Management in New England

Presentation Description: This presentation will review the cost to manage biosolids in various New England states, and the impact that PFAS has had on utilities’ operating budgets and operations for biosolids management. Maine’s land application moratorium, signed by the governor, will be discussed, including its short- and long-term impacts. The reactions of nearby states such as New Hampshire, Vermont, and Massachusetts’s to EPA’s PFAS roadmap; Maine’s moratorium; and growing negative public perception will be reviewed such that California agencies can learn from New England utilities’ experiences. We will also review successes in these states, where progress has been made working with regulators, communities, activist groups, and local legislative bodies.

EPA currently has not set any policies on PFAS in NPDES permitting, nor PFAS in biosolids. However, CERCLA has recently proposed designation of PFOS and PFOA as hazardous materials, which could impact water reclamation facilities and potential liabilities. States are taking matters into their own hands, ranging from a “do-nothing” approach to instituting a statewide ban on the land application of biosolids (Maine) which has severely disrupted biosolids management . Many states are moving toward “report only” requirements in NPDES permits for influent, effluent, and biosolids to increase the database of PFAS in the environment.

What should California do? To date, most states have not imposed PFAS standards in NPDES permits or biosolids, but Michigan’s EGLE has done precedent-setting work on PFAS in WW and mitigating sources. Utilities and consultants need to be prepared to educate communities, the legislature, regulators, and other stakeholders on the direct and indirect impacts of regulations and legislation around PFAS and water reclamation facilities. Industries discharging to WRFs need to participate in the conversation and become part of the solution through source control. In parallel, the science needs to continue to be developed and expanded, to better understand the true health and environmental implications of these compounds. This presentation aims to continue the conversation and information sharing so measured and thoughtful actions can be taken to address this issue in a fiscally and environmentally responsible manner, and so Californians can benefit from and implement the best practices.