The ASTSWMO Board of Directors approved an update to their March 2021 Position Paper on Addressing PFAS in November 2022. The paper acknowledges the work Federal and State agencies have taken to date and recommends federal regulatory action, guidance development, and further research to address PFAS.
The ASTSWMO Contaminants of Emerging Concern (CEC) Steering Committee hosted a webinar that focuses on key considerations for States interested in developing a State CEC program. On November 6, 2020, the Steering Committee gave an introductory presentation at which time we provided the ASTSWMO membership with an outline of activities being considered to further our CEC dialogue. The presentation ended with a call for input regarding questions and issues of concern from the membership as it pertains to the CEC dialogue and how we – as a Steering Committee – could further the development of successful State-led CEC programs in the absence of a federal framework. We picked up the conversation where we left off in November and digging deeper into practical considerations for developing a State CEC program.
The webinar covered several topics including internal and external engagement and collaboration, program scoping and identifying and prioritizing CECs.
ASTSWMO joined ACWA, ASDWA and ECOS in submitting a joint comment letter to EPA on its proposed rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards (EPA-HQ-OW-2020-0582) relating to the effluent limitations guidelines, pretreatment standards and new source performance standards applicable to the Organic Chemicals, Plastics and Synthetic Fibers (OCPSF) point source category to address discharges from manufacturers of PFAS.
On February 19, 2021, the ASTSWMO CEC Steering Committee submitted comments to EPA on their Interim PFAS Destruction and Disposal Guidance. Visit Docket EPA-HQ-OLEM-2020-0527 on Regulations.gov to review the interim guidance document and other supporting materials and public comments.
ASTSWMO members identified a number of issues in this paper that are current priorities for State federal facility programs. For each of the issues, ASTSWMO briefly summarizes the issues, describes current challenges identified by our membership, and offers recommendations for States and federal agencies. Additional information about the issues, including federal and State guidance and policies, previous ASTSWMO research projects, and fact sheets, are provided in the References section. ASTSWMO encourages its membership to utilize these informational resources to further inform and improve its work with federal facilities.
The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) appreciates the opportunity to provide comments on the U.S. Environmental Protection Agency’s (EPA’s) Draft Interim Recommendations for Addressing Groundwater Contaminated with PFOA and PFOS. ASTSWMO is an association representing the waste management and remediation programs of the 50 U.S. States, five Territories, and the District of Columbia (States). These comments are being submitted by ASTSWMO’s PFAS Workgroup, which includes representatives from ASTSWMO’s Board of Directors and program Subcommittees. These comments have not been reviewed or adopted by the ASTSWMO Board of Directors.
We appreciate the U.S. Environmental Protection Agency’s (EPA’s) development of its Per-and Polyfluoroalkyl Substances (PFAS) Action Plan in response to the feedback EPA received during the May 2018 PFAS National Leadership Summit and other public engagements. The Action Plan demonstrates EPA’s acknowledgment of the several challenges States, Interstates and Territories (States) are facing related to PFAS.
ASTSWMO conducted this study to identify mechanisms for evaluating ongoing protectiveness at federal facility sites that have achieved site closeout that allows for unlimited use/unrestricted exposure (UU/UE). This category of sites may present challenges for evaluating their continuing protectiveness as they are typically not subject to periodic reporting requirements or periodic State review. The ASTSWMO State Federal Coordination Focus Group requested information from the 50 States, five Territories, and the District of Columbia (States) on their management of closed federal facility sites, including State definitions of site closeout; State experiences with reopening closed federal facility sites; and, their ability to track or revisit sites that have achieved site closeout. Thirty-three States responded to our request. The analysis of State responses and a list of recommendations for States is provided in this report.
ASTSWMO prepared this paper to provide our members with information on perfluorinated chemicals (PFCs), which are emerging contaminants of concern. This document focuses on two specific PFCs – perfluorooctanioc acid (PFOA) and perfluorooctane sulfonate (PFOS) – and contains introductory information and resources on its historical and current uses, effects on human health and the environment, and current State and federal guidelines for investigation and remediation.
The ASTSWMO Radiation Focus Group developed this guidance to inform solid waste management and other officials about technologically-enhanced, naturally-occurring, radioactive materials (TENORM) concerns and management approaches. TENORM contamination is typically the result of process operations involving the extraction, purification, filtration, smelting, or pipeline transport of virtually any material of geological origin. The TENORM discussed in this guidance are not federally regulated and are incidentally concentrated from various industrial processes, such as coal mining and combustion, and water treatment. These materials have the potential to be transported to solid waste facilities or become legacy contaminants on CERCLA sites.