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dling and transporting hazardous mate-rials
and due to distance. Furthermore,
water utilities will be competing with
every other industry that disposes waste
containing PFAS for contracted space in
this lesser number of suitable hazardous
waste facilities, creating market pres-sure
that could drive costs even higher.
As an alternative to landfilling, in
some cases spent media containing PFAS
is incinerated, and GAC may be thermal-ly
reactivated. However, these residuals
management options are not immune
to the impact of a hazardous waste des-ignation
under RCRA. In addition to the
aforementioned increase in handling
costs, both in transit and at the receiving
facility, the fate of PFAS in thermal reac-tivation
and incinerator stack emissions
remains uncertain, with some studies
demonstrating atmospheric deposition
downwind. In the absence of more con-clusive
research demonstrating the con-ditions
under which PFAS are thermally
decomposed, a hazardous waste designa-tion
could prompt facilities to operate at
higher, more conservative temperatures
to avoid adverse environmental impact,
compliance violations and/or liability —
a strategic measure that would increase
operating costs ultimately passed along
to customers.
Considering the far-reaching impli-cations
of a hazardous waste designation
under RCRA, with no options for resid-uals
management entirely unaffected,
such an action would almost certainly
present cost and logistical challenges for
any drinking water utility engaged in
PFAS treatment. However, while the ef-fects
may be unavoidable, they need not
be overly disruptive for those utilities
that take proactive measures to mitigate
the impact. The following series of steps,
intentionally listed succinctly to empha-size
the straightforward nature of the
strategic approach, can immediately be
initiated by any utility to develop its own
Plan B for this contingency:
1. Assess susceptibility
2. Evaluate options
3. Prioritize alternatives
4. Identify triggers
5. Estimate costs
6. Budget funds
With these steps complete, utilities
can hold a Plan B for management of
PFAS-laden residuals in reserve pending
the implementation of a hazardous waste
designation under RCRA (and/or other
utility-specific preceding triggers), secure
in their preparedness. If the proposed
RCRA designation lingers and evolves in
its scope, the plan can be readily updated.
As the famed French microbiologist
Louis Pasteur is credited with quipping:
“Fortune favors the prepared mind.”
While the proverbial pandemic of PFAS
will persist for the foreseeable future, the
challenges are neither insurmountable
nor unmanageable with the combination
of strategic anticipation and the
willingness to act.
Brent Alspach is the director
of applied research at Arcadis.
PFAS CHALLENGES
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