PFAS Impacts on the Waste Industry BM1 and US Ecology’s Solutions Andy Marshall Executive Vice President Regulatory Compliance & Safety
Slide 1 BM1 Andy: This title, "PFAS Impacts on the Waste Industry" is how UBS is advertising this presentation." I added "and US Ecology's Solutions" Beth Mickelson, 4/1/2020
The PFAS Challenge Regulatory Environment PFAS Market & Capabilities US Ecology Solutions
Per- and polyfluoroalkyl substances (PFAS) PFAS Products Teflon Scotchguard Stainmaster Stainsafe Silverstone Polartec Texapore Gore-tec PFAS were invented in the 1930s and were the main ingredients in • nonstick and waterproof coatings More than 3,000 manmade chemicals are classified as PFAS. Most is • known about PFOS and PFOA Compounds are persistent in the environment and mobile • 3
Contamination Pathways 4
Initial Regulatory Development EPA was slow to regulate PFAS environmental impacts Recognized in early 2000s for potential health and environmental • impacts EPA published provisional health advisory (not a regulatory limit) • of 70 ppt for PFOA/PFOS in drinking water in 2009 Phased elimination of the manufacture of certain PFAS compounds • by 2015 Developed PFAS Action Plan in February 2019 • States have been leading regulatory change Requiring testing of discharges, surface and ground water to • determine extent of the problem Some states eliminating inventory and disposal of PFAS foams • from fire departments Establishing discharge limits and requiring PFAS site clean-ups • 5
Progress on EPA’s PFAS action plan (Released: February 14, 2019) February 20, 2020 released a preliminary determination to Drinking Water regulate PFOS and PFOA under the Safe Drinking Water Act Initiated regulatory process to designate PFOA and PFOS Cleanup hazardous substances Issued interim recommendations for groundwater contamination on December 19, 2019 February 20, 2020 added PFAS chemicals to the Toxics Release Toxics Inventory and proposed regulations on importing PFAS chemicals used in surface coatings Added 6 PFAS compounds to monitoring by Public Waster Monitoring Systems December 19, 2019 - Validated analytical methods for 29 PFAS Research compounds 6
Congress Acted through the NDAA (National Defense Authorization Act, December 2019) DOD Provisions include: Phase out of AFFF foams by 2024 • PFAS-containing waste must be stored according to RCRA • Controls over the incineration of PFAS waste • Requirements that drive identification and cleanup of contaminated • military installations EPA Provisions Include: Requirement to add PFAS compounds to Toxic Release Inventory (TRI) • Publish interim guidance on disposal and destruction by Dec. 2020 • Expedite research into health and environmental effects and • remediation technology TSCA amendments requiring reporting by PFAS manufacturers • What wasn't included was inclusion of a CERCLA hazardous substance designation for certain PFAS chemicals 7
Current Market Opportunities AFFF firefighting foam Disposal of the PFAS foam inventory from fire departments and DOD • Disposal of diluted firefighting foam wastewater from firefighting • activity Soil and water contamination US Department of Defense • Identified 425 military sites with high concentrations of soil and • groundwater PFAS contamination Preliminary estimate of $2 billion in cleanup costs • Managing PFAS contaminated leachate from municipal landfills • Soil and groundwater from 100’s of contaminated sites • Other PFAS waste sources Water treatment media with concentrated PFAS • 8
Potential Treatment/Disposal Options PFAS contaminated Water Technology Risks Activated carbon Treatment becomes more complicated when Ion exchange wastewater has high levels of organics. Reverse osmosis Deepwell disposal may be limited to lower Deepwell Injection concentrations due to foaming. PFAS Soil Technology Risks Thermal desorption Air emissions are in early stages of evaluation and Thermal soil burners burner temperature and residence time are parameters. Large resistance from activist groups. Commercial incineration Landfill Leachate may require PFAS treatment. 9
US Ecology PFAS waste solutions Arid Climate Landfill Disposal (Beatty, NV and Grand View, ID) No leachate discharge • Capable of high concentration, large volume event projects • Other Landfill Solutions (Belleville, MI and Robstown, TX) Accept lower concentration PFAS waste to manage leachate • treatment Thermal Soil Treatment (Moose Creek, AK) Only thermal treatment unit specifically permitted for PFAS • EPA Office of Research and Development involved in extensive testing • Adjacent to Eielson AFB with approx. 300,000 tons of PFAS soil • Deepwell Disposal (Winnie, TX) Permitted to accept municipal landfill leachate • Caprock disposal facility can accept high levels of solids • 10
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