Gorzelnik Engineering

How large of a problem are PFAS in Biosolids?

We currently don’t know how big of a problem this is although EPA is trying to find out through its National Sewage Sludge Survey, which was last held in 2006. The National Sewage Sludge Survey is working in collaboration with the publicly owned treatment works (POTW) Influent PFAS Study and will focus on PFAS.

What is a Hazardous Constituent?

A hazardous constituent is not a hazardous waste. Instead, it is anything listed in 40 CFR part 261 Appendix VIII. A hazardous constituent listing is a step toward a potential hazardous waste listing. To list a waste as a RCRA hazardous waste under 40 CFR 261.11(a)(3), the waste must contain a hazardous constituent listed on Appendix VIII and determine that it is capable of posing a substantial hazard.

Does this affect drinking water?

I do not believe so because hazardous constituents do not make themselves, or the wastes containing them, RCRA hazardous wastes. Only hazardous waste treatment storage or disposal facilities are subject to RCRA corrective actions according to 42 U.S.C. 3004(u)(v). I supposed it is possible that a drinking water plant is a hazardous waste treatment, storage, or disposal facility but that would be novel for me.

Why is it important to submit a comment?

Simply put the EPA generally listens if you have a well thought out point and it is important to participate in the laws which govern you.

How to submit a comment?

To submit comments, just click the “submit a formal comment” button as shown in the picture below. You can also view all comments submitted. Once the public comment period closes, the EPA reviews all the comments and replies to every one; I’m glad I wasn’t working on this Clean Water Rule which received over 1,000,000 public comments. Click the big green button on the middle right of the screen!