December 2024
EPA Document No. 820S24002
Stakeholder Meeting
Facilitation for Issues Related
to PFAS and Biosolids
Prepared for the U.S. EPA
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Contents
Disclaimer 3
Purpose of Report 4
Methodology 4
Perspectives on the Management of Biosolids with Respect to PFAS 6
PFAS and Biosolids Regulatory Landscape 6
Key Challenges on the Management of Biosolids 8
Opportunities in PFAS Biosolids Management 15
Conclusion 19
Appendix A: Workshop Participants 21
Appendix B: One-on-One Interview Guide 22
Appendix C: Workshop Agendas 24
PFAS in Municipal Biosolids Workshop #1 Agenda 24
PFAS in Municipal Biosolids Workshop #2 Agenda 25
PFAS in Municipal Biosolids Workshop #3 Agenda 28
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Disclaimer
Reference herein to any specific commercial products, process, or service by trade name,
trademark, manufacturer, or otherwise does not necessarily constitute or imply its
endorsement, recommendation, or favoring by the U.S. Environmental Protection Agency or of
any organizations participating in these workshops. The views and opinions expressed herein
do not necessarily state or reflect those of the EPA or participating organizations.
The EPA typically uses the term "biosolids" to mean sewage sludge treated to meet the
requirements in Title 40 of the Code of Federal Regulations (CFR) part 503 and intended to be
applied to land as a soil amendment. This document summarizes views from participants
outside the EPA where the terms are used interchangeably, so for the purposes of this report,
"biosolids" means "sewage sludge."
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Purpose of Report
The rise in concern over PFAS in municipal biosolids has created challenges and uncertainties
for publicly owned treatment works that rely on the three main biosolids management options:
land application, disposal in landfills, and incineration. These concerns have also created
challenges for land appliers and solid waste management facilities. Due to the significant
challenges facing utilities around the United States associated with the management of
municipal biosolids, the US EPA, with input from the National Association of Clean Water
Agencies (NACWA) and other stakeholders convened a series of three workshops. These three
workshops convened 21 participants representing both wastewater utilities and solid waste
organizations ("regulated entities"), state regulators, and the EPA. The original stated purpose
of these three workshops, held between October 2023 and May/June 2024 was to:
• Explore the three main management options for biosolids, their benefits and
challenges, and their ability to meet capacity and public health needs
• Identify management practices and treatment technologies to address PFAS in biosolids
• Discuss practices for, and gaps in, communication related to PFAS and biosolids
The workshops served to collect information from individual participants on considerations and
challenges with managing PFAS in biosolids. No collective advice or recommendations were
pursued or received from the meeting process. This document reports the perspectives and
contributions that participants shared across the three meetings and one-on-one discussions
between the facilitators and meeting participants and does not seek to demonstrate consensus
or offer recommendations for action.
Methodology
In August 2023, Ross Strategic was contracted by the US EPA as the third-party facilitator tasked
with assisting in the selection of workshop participants, holding one-on-one discussions with
individual participants, planning and executing the three workshops, and synthesizing notes
across the three workshops to inform this report. Below is a brief description of each of the
three methods.
• Workshop Participation: Workshop participants were selected by their individual
organizations, including the Association of Clean Water Administrators (ACWA),
Association of State and Territorial Solid Waste Management Officials (ASTSWMO),
Environmental Council of the States (ECOS), National Association of Clean Water
Agencies (NACWA), National Association of State Departments of Agriculture (NASDA),
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Solid Waste Association of North America (SWANA), and Water Environment Federation
(WEF).
• One-on-One Discussions: Prior to holding the three workshops, the Ross Strategic team
held one-on-one discussions with each of the individual participants. These discussions
were meant to gather early perspectives prior to prioritizing workshop agenda topics.
For the series of questions utilized during these discussions, see Appendix B: One-on-
One Interview Guide. Discussion questions were prioritized based on the individual
participant's experience and role.
• Workshops: The first two workshops were held virtually and the third was held in
person in Washington D.C. The workshop ordering was designed to first focus on
challenges, then opportunities to solve the identified challenges, and lastly,
opportunities for coordination. Agendas for each of the three workshops can be found
in Appendix C: Workshop Agendas.
This report represents perspectives and insights provided from both the one-on-one discussions
and across the three workshops.
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Perspectives on the Management of
Biosolids with Respect to PFAS
PFAS and Biosolids Regulatory Landscape
The EPA "Basics of Biosolids" webpage describes biosolids as the product of the wastewater
treatment process. During wastewater treatment the liquids are separated from the solids.
Those solids are then treated physically and chemically to produce a semisolid, nutrient-rich
product known as biosolids. The EPA goes on to describe that examples of beneficial use
include application to agricultural land and reclamation sites (e.g. mining sites). "When applied
to land at the appropriate agronomic rate, biosolids provide a number of benefits including
nutrient addition, improved soil structure, and water reuse. Land application of biosolids also
can have economic and waste management benefits (e.g., conservation of landfill space;
reduced demand on non-renewable resources like phosphorus; and a reduced demand for
synthetic fertilizers). Biosolids also may be disposed of by incineration, landfilling, or other
forms of surface disposal."1
Each of the three biosolids management methods (land application, incineration, and
landfilling) poses challenges as PFAS are not destroyed during the standard wastewater
treatment process. The ability of incineration to destroy PFAS is still under investigation.
Landfills may have limited capacity for the acceptance of additional biosolids. The leachate
landfills produce is a known source of PFAS released into the environment. In addition, there
are concerns with greenhouse gas generation (methane) from the landfilling of biosolids. Land
application of biosolids raises concerns about PFAS entering soils, surface water, and
groundwater and movement from soil to plants and livestock through grazing. Additionally, in
some communities there is interdependence among available management methods, and
restricted access to any one management method exacerbates the potential issues with the
other method(s).
The EPA regulates the disposal2 and use of biosolids under 40 CFR Part 503. As of publication,
there are no federal pollutant limits for PFAS in biosolids. The EPA is currently conducting a
1 Basic Information about Biosolids I US EPA
2 Disposal practices may also be regulated under solid waste or air regulations.
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biosolids risk assessment for two PFAS in biosolids: perfluorooctanoic acid (PFOA) and
perfluorooctane sulfonic acid (PFOS).3 The biosolids risk assessment is part of the EPA's PFAS
Strategic Roadmap which sets timelines by which the EPA plans to take specific actions to
safeguard communities from PFAS contamination.4 In regard to PFAS testing in biosolids, the
EPA has published the final EPA Method 1633.5 The EPA currently recommends Method 1633
for use in biosolids monitoring alongside other methods such as EPA Method 1621 for aqueous
samples.
While the biosolids risk assessment is ongoing, the EPA recommends that states monitor
biosolids for PFAS contamination, identify likely industrial discharges of PFAS, and implement
industrial pretreatment requirements where appropriate. Doing so will help prevent
downstream PFAS contamination and lower the concentration of PFAS in biosolids as described
in Section C of the EPA's December 2022 memo entitled "Addressing PFAS Discharges in NPDES
Permits and Through the Pretreatment Program and Monitoring Programs."6
Actions regarding PFAS not directly related to biosolids but closely related that the EPA has
taken recently include: published updated interim PFAS destruction and disposal guidance7;
adopted National Primary Drinking Water Regulations for six PFAS8; proposed regulations that
would add nine PFAS as hazardous constituents under the Resource Conservation and Recovery
Act9; announced through the Effluent Guidelines Program Plan 15 that the EPA will 1) revise the
existing Landfills Point Source Category Effluent Limitation Guidelines to address PFAS in landfill
leachate and 2) conduct a POTW Influent study that will focus on collecting nationwide PFAS
data on industrial discharges to POTWs as well as PFAS monitoring in biosolids.10
The EPA is the permitting authority for 41 states and implements a federal biosolids program
under 40 CFR 503. In nine states, Arizona, Idaho, Michigan, Ohio, Oklahoma, South Dakota,
Texas, Utah and Wisconsin, the state are the authorized NPDES permitting authority for
3 Risk Assessment of Pollutants in Biosolids I US EPA
4 PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024
5 CWA Analytical Methods for Per- and Polvfluorinated Alkvl Substances (PFAS) I US EPA
6 Memorandum Addressing PFAS Discharges in NPDES Permits and Through the Pretreatment Program and Monitoring Programs I US EPA
7 Interim Guidance on the Destruction and Disposal of Perfluoroalkvl and Polvfluoroalkvl Substances and Materials Containing Perfluoroalkvl and Polvfluoroalkvl
Substances-Version 2 (2024) I US EPA
8 89 Fed. Reg. 32532 (April 26, 2024).
9 89 Fed. Reg. 8606 (February 8, 2024).
10 Current Effluent Guidelines Program Plan I US EPA
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biosolids.11 Regardless of whether a state is the authorized permitting authority, States are not
precluded from imposing requirements for the use or disposal of sewage sludge more stringent
than the Part 503 rules, or from imposing additional requirements for the use or disposal of
sewage sludge.
States have taken a variety of actions to manage PFAS in biosolids either directly affecting
biosolids or other types of regulatory actions such as sampling and monitoring requirements.
Maine is the only state with a ban on land application of biosolids (Connecticut announced a
ban on a land application of biosolids with detectable PFAS shortly after the meetings).12 New
Hampshire, Massachusetts, and Michigan have reporting requirements for monitoring PFAS in
biosolids.13 Michigan has tiered levels for PFOS in sewage sludge for land application that
require different actions and has worked to identify industrial releases. While many States have
not adopted specific requirements related to PFAS in biosolids, some state regulators have
recommended voluntary testing and permittees may be engaged in voluntary monitoring
programs to better understand PFAS coming into treatment plants and remaining in biosolids.
There are also county, municipal, and other jurisdictions with regulatory authority that can
affect biosolids management. This can create a complicated regulatory regime for municipal
wastewater utilities to navigate.
The unique challenges and uncertainties presented by PFAS in biosolids were recognized in the
Joint Principles for Managing PFAS in Biosolids ("Principles") developed jointly by the EPA, the
Environmental Council of the States (ECOS), and the National Association of State Departments
of Agriculture (NASDA).14
Key Challenges on the Management of Biosolids
The management of biosolids is highly dependent on the location, due to the different
constraints, regulatory environments, and capacity of a given municipality, state, or region. The
participants at this series of workshops brought their own individual perspectives on challenges
they face regarding the management of biosolids. It should be noted that the relative use of the
three management options (land application, incineration, and landfilling) varied greatly
11NPDES State Program Authority I US EPA
12 Maine does allow land application of septage and provides exemptions for biosolids for some products like compost or other agricultural products. PFAS in
Biosolids: A Review of State Efforts & Opportunities for Action, p. 4 (ECOS 2023)(Available at: PFAS in Biosolids: A Review of State Efforts & Opportunities for
Action).
13 PFAS in Biosolids: A Review of State Efforts & Opportunities for Action, p.8 (ECOS 2023)
14Joint Principles for Preventing and Managing PFAS in Biosolids (epa.gov)
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amongst the group. Whereas some individuals lived in areas that relied on a mix of all three,
others lived in regions where two or only one management option was utilized. Responding to
a disruption in the management chain of biosolids due to PFAS is particularly challenging due to
interconnectedness of the system, and regional/local constraints. Ultimately, participants
stressed that maintaining viability of all three management options relieves stress on the
system.
This section outlines cross-cutting challenges that the workgroup participants highlighted,
regardless of the mix of management options utilized, as well as specific challenges associated
with each of the management options.
Cross Cutting Challenges
Uncertainty across management options has led to a regulatory patchwork which fills the
space of no national standard.
Across all three management options, there is scientific uncertainty. The fate of PFAS in
biosolids which are incinerated is still being studied, the risk of land application of biosolids
containing PFAS is yet to be fully understood, and technologies to remove PFAS from leachate
in landfills and wastewater operations are still being explored and tested for effectiveness. All
these unknowns have led many regions and municipalities to respond in different ways to
emerging events. Workshop participants often highlight Maine as an example of this, where
testing and discovery of PFAS in farming and dairy operations led to the ban of land application
of biosolids across the entire state. Participants noted that while individual states implement
regulations, biosolids and products derived from biosolids move between and across state lines
which can make it complicated for operators to know which rules and regulations to follow.
Because states are, in many cases, responding to discrete events, the regulatory environment is
varied, creating a patchwork of local ordinances and rules that make it challenging to
understand how to manage biosolids with detectible levels of PFAS to minimize risk.
Participants hoped that the exposure and risk from biosolids would be viewed in comparison
with other PFAS exposure pathways.
Sampling, testing, and monitoring for PFAS in the waste system to date has been constrained
by the absence of recommended methods and limited availability of testing facilities.
Determining PFAS concentrations in the wastewater stream is essential to understand the
scope and scale of the issue in a municipality. However, participants noted that the challenges
associated with identifying and distinguishing PFAS from domestic and industrial sources. Many
workshop participants have been working to characterize PFAS in their waste streams through
sampling and/or testing from industrial facilities, commercial activities, and in residential areas.
This has required dedicated funding to carry out through states or through regular budgets.
Costs per sample can be quite high, with one participant noting the cost to be $450 to $550 per
sample. However, even if funding is available, it can be a challenge in some regions to find labs
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that can conduct the analysis. Some stakeholders have sent samples to colleges, environmental
organizations, or non-profits but participants were concerned that the analysis was not always
reliable. When participants did have reliable labs to conduct the analysis, the turnaround time
could range from 45 days to up to five months. Additionally, though EPA Method 1633 is
recommended for use by the EPA for detecting PFAS in biosolids, participants were concerned
with the number of labs currently available to run the method.
There is an unaddressed issue related to rural communities that have significant use of private
wells - no one has strong purview over monitoring risk associated with private wells. Though
not directly related to the responsibilities of water and waste utilities, it is still an important
consideration noted by the participants.
Opportunities to test and better understand the presence of PFAS in biosolids is limited by
liability concerns across the board.
Sampling, testing, and monitoring for PFAS in biosolids across different media (e.g., landfill
leachate, agricultural soils) would help gain a clearer picture of the issue in different regions. In
the absence of required monitoring and clear regulatory standards on how to conduct testing
and sampling, analyses may be unreliable. Additionally, participants expressed that liability
concerns around receiving biosolids with PFAS can disrupt the management chain.
Some workshop participants felt that in the absence of required monitoring for PFAS, there is
concern by wastewater operators and landfill operators to begin testing for PFAS in the
wastewater, biosolids and landfill leachate. They noted that though it would be good to
understand its presence or absence, there are significant liability risks if they do find PFAS in
samples. Because there is no national regulatory standard by which to take action and no
existing guidance to consistently communicate risk, workshop participants expressed that if
they do monitor and find PFAS in samples, it could open the facilities up to public backlash or
lawsuits from residents or NGOs in the short-term.
For landfills, participants noted that waste operators may be hesitant to accept potentially
contaminated materials. If they do accept contaminated materials, they may have limited
options for leachate acceptance by wastewater treatment plants due to due to concerns of
liability by wastewater operators. Pre-treating leachate also comes at a significant cost, and
landfill operators' decision to accept contaminated waste - and the potential liability that
comes with it - may be a cost-benefit decision until clear regulatory standards are put in place.
Without contribution of funds by industry (i.e., those who may be driving high PFAS levels) to
support treatment, it may not be economically viable and the cost of implementing new
treatment technologies would likely be borne by water utility and landfill rate payers.
In the event an agricultural producer has exposure to PFAS in biosolids via land application, the
producer may take on liability issues and risk, with a potential need to extensively modify or
end agricultural operations. This may lead to a hesitancy to utilize biosolids or hesitancy to
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allow testing of their land over time. The participants expressed concern that in the absence of
clear regulatory standards and risk of PFAS uptake in agricultural products, any PFAS presence
can risk a farmer losing business because of perceived risk or damaged reputation of the
operation.
Maintaining public trust of utility systems requires consistent communication on risk.
Poor risk communication can negatively influence public perception and drive fast reactions in
relation to the management of biosolids. Many participants spoke about how public perception
has harmed agricultural business and could create liability for users of biosolids. Participants
often stressed that consumers may find it difficult to understand the PFAS in products they use
at home can translate to broader risks from PFAS in other parts of the product life cycle (i.e.,
biosolids or landfill leachate). As we continue to better understand biosolids land application
through ongoing studies, such as research by the EPA and others to better understand PFAS
uptake by crops, participants noted that ongoing and consistent communication with the public
is key to maintaining trust and understanding of how management professionals are working to
reduce risk to users of biosolids.
Communication must be targeted at a variety of audiences, including utility customers, state
and local governments, industry, non-residential contributors to wastewater treatment plants
(e.g., schools), and farmers. This is going to require tailoring information that is accurate and
relevant to each individual audience's interests. Currently, communication of risk associated
with biosolids falls on wastewater operators and other users and disposal managers, who are
already time constrained within their existing responsibilities and roles. Without clear,
consistent messaging on risk of PFAS in biosolids, there may be domino effects that impact the
whole system. At present many utilities undertake proactive communications designed to
educate their customers and stakeholders on actions being taken on PFAS, where a given
facility's PFAS concentrations may fall within the range of facilities and media across the region,
as well as information on exposure pathways and how to reduce exposure, and the ability of
utilities and customers to reduce their use of PFAS-containing materials. Utilities are aware of
and working to educate their customers as the public perception of potential PFAS
contamination may influence farmers to halt their use of biosolids, which would reduce
demand for biosolids and lead to a need to find other disposal options. In the event that there
is low risk associated with land application of biosolids, this needs to be communicated to
prevent public pressure to remove it as an option. In the event there is a significant human
health risk associated with land application of biosolids, this needs to be well understood and
communicated with relevant stakeholders.
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Without proper source control, PFAS will continue to enter the waste system for years to
come.
A significant theme across all three workshops was the pressing and urgent need for source
control of PFAS, which has commonly been in consumer products and industry for decades.
Without limiting or removing PFAS from products that are destined for wastewater utilities or
landfills (which ultimately enter wastewater utilities though leachate), it will continue to enter
the wastewater treatment system. It is worth highlighting stakeholders acknowledged that
even if PFAS were to stop being used in products, legacy PFAS would still need to work their
way through the wastewater treatment system for a significant period of time. Utilizing
treatment and removal technologies was often described as a costly "short-term" fix to the
larger issues of PFAS in products and industrial discharges.
Source control begins with understanding source contributions from industrial, commercial,
and residential sources. Identifying sources of PFAS in the waste systems offers opportunities to
understand the scope and scale of the problem. Examples of methods to identify sources are
provided below. However, source identification and control have their own associated
challenges. Namely, the scale of testing and monitoring needed for PFAS requires financial and
human resources. Participants felt that resources are already constrained and to undertake this
type of endeavor across municipalities and states would require dedicated funding flows, either
from PFAS manufacturers and users or from other means, such as state legislatures.
A second issue, particularly in the case of residential source contribution, is that even if sources,
such as school cleaning programs or carpet cleaning are identified, the role wastewater and
landfill operators can play is limited. The operators can participate in education and
communication, which some noted they are already doing, but it is not a long-term fix. As long
as PFAS continue to be in products, wastewater operators and landfill operators will continue
to receive inputs of these "forever chemicals" with few options for reducing these inputs.
Land Application Challenges
Land application bans have the potential to disrupt waste management systems, as risks are
still being better understood.
Participants in workshops noted that their primary role is to provide services (i.e., solid waste
management and wastewater treatment) to communities and managing risk to the public is a
core component of their work. Multiple participants spoke about existing biosolids programs
which distribute biosolids to farmland. In some cases, farmers are paid to take the product, and
in other cases farmers pay a comparatively low price for it (as opposed to traditional fertilizers).
In either case, biosolids programs take these actions to reduce volumes going to landfill and
save costs by avoiding tipping fees. Balancing risk with the benefits the waste system provides
is a challenge, particularly in the face of biosolids land application bans which require significant
adjustment of waste flows. State regulators described programs they have developed to
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investigate biosolids and pursue source control approaches in order to maintain land
application. Some participants discussed that because EPA has yet to set limits and provide
enough information on risk from PFAS in biosolids, individual states have had to respond with a
patchwork of regulatory frameworks. In the workshops it was suggested that given the public
perception and perceived liability of PFAS in biosolids in particular in the land application
context, it is essential that EPA provide information on limits based on science and with
transparency about why certain decisions are made. One participant noted that Part 503
regulations have risk-based levels for several constituents in biosolids already that are related
to management practices, and this type of framework can be helpful as it allows practitioners
to think of the relative risk of land application and ultimately use it as a tool for communication.
As mentioned above, participants want to maintain their management options for biosolids
which includes the option to land apply. In order to do this, it is essential that risk of land
application is well understood to best maintain it as a management option and protect public
health to the fullest extent.
Lane allonges
Landfill capacity across different regions and opportunities to site new landfills are limited
Limited landfill capacity was often cited as a significant challenge during one-on-one discussions
with participants and was noted as the most likely challenge to impact the long-term viability of
landfill management in the workshops. The amount of space available in existing landfills is
constrained and biosolids destined for landfills need to either be dried to reduce volume (which
takes a lot of energy) or add bulky materials to stabilize it (which takes more space).
Participants noted that though volume reduction can be a solution in the short-term, it will not
solve the long-term issue of limited landfill capacity and does not reduce the amount of PFAS
going into the landfill. Some facilities need to add bulky dry material for stability, which creates
more volume and further constrains landfill capacity. In some cases, landfill operators can only
accept a certain percentage of sewage sludge in their intake and certain areas of the country
are struggling to obtain sufficient landfill space for other solid waste disposal. Adding to the
limited space in existing landfills, the opportunity to site landfills, particularly in population
dense regions like the Northeast, is constrained by public disinterest and lack of land
availability.
Landfilling biosolids is already utilized as a backup option by some participants in the event of
incinerator shutdowns or an inability to land apply (e.g., treatment train disruptions). As landfill
capacity declines and other management options became less available to waste management
professionals, it could create a serious disruption in the waste management system. From the
perspective of landfill operators in the workshops, it is the responsibility of states and
communities to resolve the larger issue of waste generation and disposal/recycling plans.
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Handling of PFAS containing materials is unstandardized and removing PFAS from the system
will require significant infrastructure investment
The procedures for accepting and handling PFAS-containing materials are not standardized, but
rather reflect an individual landfill's operating plans. When incineration and land application
are not available, states are faced with limited management options. In some cases, no more
than 10% of the total waste stream of these landfills can be sewage sludge and the ratio of
bulking material needed for sewage sludge can vary by landfill. Some stakeholders' landfills
were seeking to impose a limit on biosolids being taken in to reduce PFAS intake, but this
approach could prove tricky to implement and may not reduce the total amount of PFAS
entering the system. For example, participants shared that household items (e.g., couches) sent
to landfills can contain higher concentrations of PFAS - orders of magnitude higher than the
limits that are being proposed by states, localities, or landfills for biosolids. Finally, several
participants, as a method for managing PFAS, mentioned solidifying PFAS and placing them in
the landfill and discharging leachate into deep injection wells. The absence of standardized
methods for handling solid waste and PFAS contained in solid waste has led to a patchwork of
methods across states and individual landfill operations that may or may not be effective at
managing the issue.
Leachate management is a significant challenge and the movement of leachate between
wastewater operations and landfills can be circular. Leachate is produced via the landfill, goes
to wastewater treatment plants, and can return to the landfill in biosolids. Leachate generated
by landfills can contain high amounts of PFAS that can be removed through treatment, though
not through traditional wastewater treatment. Current landfill leachate treatments are still
being researched for effectiveness of PFAS destruction. Though cycling of leachate between
wastewater utilities and landfills can keep the circular waste system in place (if all biosolids are
landfilled and not land applied), it does not address the need to reduce PFAS from upstream
sources. Restrictions on discharging leachate to POTWs, because of concerns related to PFAS in
biosolids, runs the risk of further complicating biosolids management.
Technology to remove or destroy PFAS in leachate is developing, and coordination between
POTWs that need landfill capacity to dispose of their biosolids, and landfills that need leachate
acceptance will facilitate development of leachate treatment. While there were a number of
treatment technologies discussed, the top three technologies shared were foam fractionation,
reverse osmosis, and granular activated carbon (GAC). Pilot programs on foam fractionation
were discussed. Foam fractionation operates by PFAS attaching to the head of microbubbles
formed in the foam. It works best for longer chains of PFAS but not necessary for short chains.
Another pilot foam fractionation for leachate project involves the distribution of $10 million
over the next five years within a state to test the treatment method's effectiveness and
application to leachate and support regular maintenance activities. Despite its promise, the end
life of the foam is often returned to the landfill, and one stakeholder expressed concern that
this will result in just moving the problem further down the line. Other promising efforts are
working with GAC with leachate. However, there are tradeoffs such that GAC works quite well,
but it has limited storage capacity and must be replaced. Reverse osmosis has high removal
efficiency; however, it generates a concentrated end product that then needs to be managed.
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There are new planning tools becoming available that can model PFAS entering the wastewater
plant and evaluate cost and environmental issues at each management decision point. One
stakeholder demonstrated undertaking this planning process with a municipality which allowed
them to evaluate combinations of landfilling and land applying and take into consideration
leachate treatment and PFAS disposal costs. This approach allows the entity to truly consider
the management of the PFAS throughout its lifecycle from the time it enters the wastewater
treatment plant. Using innovative planning tools like this to coordinate PFAS management
between POTWs and the other stakeholders will be a critical in the future but is not currently a
widely available approach.
Incineration Challenges
The fate of PFAS in incinerated biosolids is uncertain
Multiple participants noted that there is a significant amount of uncertainty around air
emissions, deposition, and whether PFAS are fully destroyed in sewage sludge incineration.
Ultimately, it is unknown whether many incinerators operate at a high enough temperature or
residence times to achieve full PFAS destruction. PFAS could also be ending up in ash or the air.
Participants felt that improved testing methodologies for incinerators, further research on PFAS
and air emissions, and better understanding of fate and transport of PFAS via incineration
would be beneficial to alleviate this challenge.
Incinerators may be unreliable, costly to maintain, and opportunity to build new incinerators
is limited
Multiple participants noted that incinerators are often old, and subject to frequent shutdowns
for maintenance. The unreliability of incinerators as a consistent management practice is
challenging as biosolids will often need to be managed with a different option during these
times. On top of that, incinerators operate at high temperatures (800 - 1700 degrees F), which
results in high energy use and costs. While some regions favorably utilize incinerators, it is not
often viable for regions that do not readily have the available infrastructure. Incinerators are
not only expensive to run, but associated permitting and building of new incineration facilities
is costly. In addition, getting permits approved for new facilities is challenging given air
emissions standards for pollutants other than PFAS. If a state does have incinerators already,
retrofitting with new technologies can be very costly. Participants were not aware of federal
infrastructure funding for incineration waste management.
Opportunities in PFAS Biosolids Management
Though there are significant hurdles regarding the management of biosolids with or without
the added complication of PFAS, the workshops also clarified a few significant opportunities to
better manage the situation. In general, there was a large interest in continued coordination
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and learning among the group to continue understanding how individuals are responding to
PFAS in the waste stream across the United States. The opportunities described were both
collaborative in nature and technical and are outlined below. This section highlights
opportunities elucidated by the workshop participants that are cross-cutting and applicable to
all three management options and one that is specifically a technical solution that could be
pursued.
Clear analytical methods and procedures for sampling, testing, and monitoring can enable
better management and source control of PFAS
Many participants identified information gathering about PFAS levels and sources in their
wastewater streams as an important tactic in positioning themselves to make decisions about
current PFAS management strategies, reducing sources of PFAS, preparing for an unknown
regulatory landscape, and improving their communication with stakeholders. Approaches to
testing and monitoring differ among POTWs, but all are focused on gathering as much
information possible given resource constraints, to either reduce PFAS levels in biosolids,
prepare for future reductions, or be responsive to regulator and public requests for
information.
Multiple stakeholders used a process of identifying industrial sources of PFAS in their waste
streams through sampling and/or testing. Two stakeholders took a ranking approach to their
sampling and testing processes. One stakeholder from a POTW described their ranking
approach which started with testing over 150 industrial facilities and their effluent.
Concentrations of PFAS in effluent and the volume of total mass released from facilities were
then utilized to rank facilities in terms of priority. A similar approach expressed by another
participant involved testing municipalities' influent, and then prioritizing facilities into rankings
of low, medium, and high. PFAS-specific plans can be developed for medium and high priority
facilities. This stakeholder and the municipalities are looking to understand what potential
industrial users are within the collection system.
Another participant provided information about a PFAS source identification approach that
utilized standard industrial classification (SIC) codes for industrial discharges. Annual sampling
and testing at industrial facilities can be identified by SIC codes. Another participant conveyed
an early risk program that involved monitoring industries that discharge into indirect potable
reuse facilities and targets facilities that are discharging a range of chemicals/pollutants,
including PFAS.
A key point raised by multiple stakeholders is the importance of maintaining good relationships
with industries contributing to the waste stream as they go through efforts to identify and
reduce sources of PFAS into the collection system, particularly in the context of not having
defined regulatory limits for industries' discharges. One stakeholder stated that leaning into
areas of mutual benefit and collaboration can support this effort, and another participant
referenced utilizing agreements of understanding to reduce PFAS in the absence of
requirements/regulations.
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Testing and identifying residential sources of PFAS in the waste stream is an important source
of information for a POTW; however, sampling and identifying residential contributions of PFAS
can be challenging given the number of homes, potential other sources (e.g., commercial
entities not classified as industrial), and facilities in a given area. One participant found that
testing for PFAS in various residential community sewer systems found differences by up to
three orders of magnitude, even when there was not an identified industrial contribution. Two
stakeholders mentioned that levels can be influenced by the presence of schools or hotels,
particularly when janitorial waste is not containerized. One stakeholder is working with schools
and hotels to better contain their waste, in particular when those facilities use septic systems,
in order to reduce any potential contamination of nearby wells.
The suggestion was made by one stakeholder that a national database on residential sources,
providing information such as the PFAS levels found with numbers and sizes of homes, would
be helpful to municipalities so they could extrapolate testing results from other locations to
reduce the amount of time and money on residential source testing.
Monitoring Costs
Monitoring for PFAS—sampling, testing, generating data, and reporting data—and identifying
their sources from waste streams takes time and financial resources. Alternative approaches to
financing PFAS sampling, testing and monitoring that were used by participants included:
• Engaging in a cost share with the state and region.
• Testing is done at the cost of the POTW for existing dischargers, while new contributors
are responsible for paying for their own PFAS testing.
• Obtaining funding through state legislation for monitoring with biosolid permit holders.
• Working with research institutions that want to develop PFAS data.
• Adding PFAS monitoring and pre-treatment language to NPDES or state permits.
Stakeholders noted that communicating with POTW customers and PFAS contributors now will
be an advantage towards compliance with any potential future regulations. Challenges around
testing, sampling and monitoring in addition to cost include reliable trained sample takers and
turnaround times for labs that can use the appropriate methods. In some cases, utilities are
hesitant to conduct monitoring voluntarily due to potential liability ramifications. Though
participants noted they are striving for transparency when they do conduct sampling and
analytical detection and data generation it can be challenging, particularly when sampling land
application sites, to avoid negative impacts to agricultural producers. Other stakeholders have
been utilizing monitoring data to educate and inform legislators and the public about the
current state of the prevalence of PFAS.
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Coordinating on clear, consistent communication can assure the public of safety and build
trust
Every individual participant highlighted that they are involved in communicating about PFAS
and biosolids to their communities. Stakeholders noted that there is not enough public
awareness of the necessity for waste management infrastructure and the potential
consequences of PFAS regulations on existing systems. However, there is an opportunity to
educate communities on the role of clean water systems and the importance of environmental
protection as a catalyst for raising public awareness. Improved communications on PFAS in
biosolids is seen as a critical component of all future scenarios for managing PFAS in biosolids.
Critical audiences for communications include the entire range of stakeholders: the general
public, utility customers, utility employees, septage haulers, community groups, policy makers,
state regulators, farmers, well owners, and the media. Information sought- by the general
public and ratepayers and important for building trust and transparency include: information
on risk, and providing information that is most critical for residents, such as actions being taken
on PFAS by different utilities, where a given WWTP may fall within the range of WWTPs across a
broader region with regard to PFAS levels, and the benefits/services provided by utilities to the
public. Additionally, information on public exposure pathways and how to reduce exposure,
and the ability of utility and customers to reduce their use of PFAS-containing materials are
communications that can inform the public and reduce the overall need for management of
PFAS in biosolids. Communications for POTWs should focus on technical information, available
resources and tools (e.g., map of state resources available to address PFAS, training materials
and protocols on sampling, information on classes to perform sampling compliant with permit
conditions) and providing a space to contribute data from monitoring and testing efforts at
different facilities. Communications for policy makers (legislators) should focus on presenting
the challenges of limited management options, resources and methods available to regulators,
and the results of investigations and assessments. Communications for farmers should focus on
describing what PFAS is and how much is generally contained in the biosolids they are accepting
in order to maintain flexibility in managing crops and maintaining viability of farms.
Communications for well owners should focus on how to test their well or apply for a state
funded well sample, and information about how to understand what the sample means. A
communication tool offered to customers, community groups, and the public as well as
policymakers and media is tours at facilities and demonstration gardens.
The media plays an important role in conveying information about local governmental actions
to communities, and the POTW and media relationship is very important. If a relationship can
be developed where the media trusts the POTW or state regulators as source of information,
when there is an event relating to PFAS and biosolids, the POTW as an expert on the topic can
get its information out to the public quickly and the media would trust that the information is
accurate.
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Messaging consistency and coordination between the EPA, states, and POTWs offers
opportunities to provide clear, consistent information that can inform decision-making by
policy makers and the public, while creating an understanding of the dynamic challenges that
currently exist for managing PFAS in biosolids.
Continued coordination between the EPA, states, and POTWs can help everyone better
manage and respond to the issue of PFAS in biosolids.
All stakeholders in the workshops expressed a desire for continued coordination— between the
EPA and states; the EPA, states and POTWs; and POTW-POTW. Collaboration regarding new and
emerging technologies for PFAS management, biosolids processing, testing, sampling and
monitoring, source reduction, and communications are all topics where there is interest for
POTWs to continue learning from each other. Coordination with the EPA could be centered on
maintaining consistent messaging to the public, both before and after the EPA's PFOA/PFOS
biosolids risk assessment is finalized. There is some concern amongst stakeholders on how to
provide consistent and transparent communication around what a risk assessment does and
does not do, and how it relates or not to regulatory limits. Continued coordination with the
EPA, states, and POTW could be used to provide information sheets and messaging that POTWs
could utilize in communicating with customers, farmers, and the public.
Given the public perception and perceived liability of PFAS in biosolids, it is essential that
coordinated messaging from the EPA and utilities provides information based on sound science,
while being transparent about why certain decisions are being made.
Conclusion
The dialogue in this workshop series provided an important opportunity for participants across
the regulated and regulator communities to better understand from each other how to
navigate current uncertainties, to share knowledge and expertise, and to identify efforts
needed to maintain the range of options to manage municipal biosolids that contain PFAS
safely and effectively. The experiential and anecdotal information from participants on
challenges in managing PFAS in biosolids provided critical insight into the day-to-day
practicalities involved with managing this material in the current regulatory and social context,
as well as the challenges of longer-term decision-making and planning that must be undertaken
with limited information on the future regulatory environment. The discussions illustrated the
balance among the three management options and the series of consequences that affect that
balance when one option becomes restricted.
The experiences offered by participants demonstrated that continued communication,
collaboration, and coordination will be crucial as sustainable pathways for managing biosolids,
including safely addressing PFAS, continue to be developed. Monitoring, source control, and
continued innovation are essential activities to maintaining all three management options and
are all strategies that will be facilitated by coordination and communication. Participants
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identified coordination on collecting and managing information related to PFAS in biosolids as
an opportunity for data collection to benefit the larger regulator and regulated community.
Building trust and relationships between the key parties will be critical during the next phase of
biosolids management as the risk profile and potential regulatory framework is developed.
Good relationships and communication will facilitate effective implementation of any future
regulatory structures with sensitivity to impacts to current approaches. As PFAS concerns have
grown across communities and in the public consciousness, communication with stakeholders
such as those represented in this convening is critical. However, additional communication with
other federal and state agencies, industry sectors, communities and local governments, and
advocates will be essential to ensure the public has accurate and comprehensive information.
This broader coordination and communication will help the regulated, regulator, and
potentially impacted communities navigate biosolids management in the future.
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Appendix A: Workshop Participants
The following list includes participants that joined the workshops, either virtually or in-person,
and their professional affiliation. This list does not include individuals who joined the workshop
in an observer capacity.
Participant
Affiliation
Anthony Drouin
New Hampshire Department of Environmental Services
Arie Kremen
Tetra Tech
Brent Herring
KC Water
Chris Peot
DC Water
David Tobias
U.S. EPA
Emy Liu
Iowa Department of Natural Resources (Formerly); U.S.
EPA (Currently)
Haley Falconer
City of Boise
Ivan Cooper
Civil & Environmental Consultants, Inc.
Martin Robinson
U.S. EPA
Jamie Heisig-Mitchell
Hampton Roads Sanitation District
Sec. Jeff Witte
New Mexico Department of Agriculture
Jen Lichtensteiger
New England Interstate Pollution Control Agency
Kasey Kathan
Vermont DEC
Kerry Callahan
ASTSWMO
Maggie Macomber
Charlotte Water
Matt Klasen
U.S. EPA
Mickey Conway
Metro Water Recovery (CO)
Millie Garcia-Serrano
Massachusetts Department of Environmental Protection
Rick Burns
NTH Consultants
Rob Devlin
South Carolina DHEC
Sally Rowland
NY State Department of Environmental Conservation
Scott Firmin
Portland Water District (ME)
Sherry Bock
Minnesota Pollution Control Agency
Stephanie Kammer
Michigan EGLE
Susanne Miller
Maine DEP
Tom Sigmund
NEW Water (Green Bay, Wl)
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Appendix B: One-on-One Interview
Guide
Note: The following questions explored the three main biosolids management options: land
application, incineration, and disposal in landfills. Interviews focused on the questions related
to management options or issues with which participants were most familiar. At the start of the
interview, questions were prioritized to best utilize the time.
Interview Questions
1. How do you and your sector most acutely experience the PFAS in municipal biosolids
issue?
2. What are the two or three most important conversations you think we should have?
Management Option: Land Application
3. From your perspective, how would you characterize the current state of land application
of biosolids?
4. How would you characterize the long-term viability of land application of
biosolids? What could weaken the long-term viability of land application of biosolids?
What could strengthen it?
5. What thoughts do you have (or have you heard) regarding the public health impacts of
land application of PFAS-containing biosolids? What practices are you aware of that can
help mitigate these concerns?
6. What are important conversations regulators and regulated entities need to have
regarding land application of biosolids?
7. What opportunities exist for land application of biosolids? What would have to happen
to maximize this opportunity?
Management Option: Disposal in Landfills
8. From your perspective, how would you characterize the current state of biosolids
(sewage sludge) management in landfills?
9. How would you characterize the long-term viability of landfilling biosolids? What could
weaken the long-term viability of landfilling biosolids? What could strengthen it?
10. What thoughts do you have regarding the public health impacts of landfilling biosolids?
What practices are you aware of that can help mitigate these concerns?
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11. What are important conversations regulators and regulated entities need to have
regarding landfilling biosolids?
12. What opportunities exist for landfilling biosolids? What would have to happen to
maximize this opportunity?
Management Option: Incineration
13. From your perspective, how would you characterize the current state of the incineration
of biosolids (through sewage sludge incineration)?
14. How would you characterize the long-term viability of this management by the
incineration of biosolids? What could weaken the long-term viability of incineration of
biosolids? What could strengthen it?
15. What thoughts do you have regarding the public health impacts of incineration? What
practices are you aware of that can help mitigate those concerns?
16. What are important conversations regulators and regulated entities need to have
regarding the incineration of biosolids?
17. What opportunities exist for the incineration of biosolids? What would have to happen
to maximize this opportunity?
Overarching Questions
18. From your perspective, what are the 1-2 most important factors or considerations for
addressing PFAS in municipal biosolids by the EPA?
19. From your perspective, what are the 1-2 most important factors or considerations for
addressing PFAS in municipal biosolids for State Regulators?
20. From your perspective, what are the 1-2 most important factors or considerations for
addressing PFAS in municipal biosolids by wastewater system operators?
21. From your perspective, what are the 1-2 most important factors or considerations for
addressing PFAS in municipal biosolids by the waste management professionals?
22. From your perspective, what critical gaps exist in current communication practices
related to PFAS and biosolids? Do you have any suggestions of how to best fill these
gaps?
23. What questions and/or additional information do you have for EPA and/or other actors
engaged in this process?
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Appendix C: Workshop Agendas
PFAS in Municipal Biosolids Workshop #1 Agenda
On October 25, 2023, from 11:30am - 4:30pm EST, EPA convened a virtual workshop to discuss
challenges and opportunities related to the management of PFAS in biosolids. The workshop
participants represent state regulators and wastewater and waste management regulated
entities and three EPA participants. The workshop also included observers.
October 30th 11:00am - 4:30 pm
11:00 am Welcome, Get Settled, Ground Rules, and Agenda Review
11:10 am Icebreaker Exercise (25 mins)
11:35 am Current EPA Activities and Timeline (30 presentation + 15 Q/A)
• EPA share with workshop participants the current timing and status of key PFAS and
Biosolids related work.
o Risk Assessment Work
o Source Reduction and Pre-Treatment
o The national picture of management options/current practices,
o PFAS work in other parts of EPA that are connected to our workshop.
12:20 pm Landfill Challenges: Root Causes, Impacts, and Strategies for Managing Uncertainty
• In plenary, participants will answer a series of poll questions about challenges, root
causes, impacts, and strategies for managing uncertainty with the landfill management
option. Workshop participants will dissect and discuss poll results.
1:35 pm Break
1:55 pm Land Application Challenges: Root Causes, Impacts, and Strategies for Managing
Uncertainty
• In breakout groups, participants will discuss challenges, root causes, impacts, and
strategies for managing uncertainty of the land application management option.
3:30 pm Incineration Challenges: Root Causes, Impacts, and Strategies for Managing
Uncertainty
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• In plenary, participants will answer a series of poll questions about challenges, root
causes, impacts, and strategies for managing uncertainty. Workshop participants will
dissect and discuss poll results.
4:15 pm Next Steps
PFAS in Municipal Biosolids Workshop #2 Agenda
On March 19 and 20, 2024, from 11:30am - 4:30pm EDT, U.S. EPA's Office of Water convened a
second virtual workshop to discuss participants' individual feedback on the challenges and
opportunities related to the management of PFAS in biosolids. The workshop participants
represent state regulators, wastewater and waste management regulated entities, and three
EPA participants. The workshop also included a number of observers.
March 19th 1130a-430p ET
11:30a
Networking, Welcome, and Agenda Review
11:50a
Soui trol and Source Reduction Strategies
Strategies for managing industrial sources
o What strategies has your city/municipality used to identify industrial users
discharging PFAS?
o If/how do wastewater treatment facilities use industrial user inventories to
address the PFAS challenge?
o How have you attempted to reduce the amount of PFAS received from those
industrial sources? If so, how?
o What barriers exist for Control Authorities (POTW, state, or EPA), to more
aggressively pursue reductions from industrial users?
Strategies for managing domestic sources
o What monitoring strategies have you used to identify/mitigate PFAS in the
waste stream?
o What strategies have wastewater treatment plants used to manage
domestic sources?
l:10p
Progress on other EPA PFAS efforts sine orkshop
A. EPA Presentation on Relevant PFAS Roadmap actions + Q&A
o Recent EPA PFAS Roadmap Actions
o EPA Methods 1621 and 1633
¦ ELG program updates
2:00p
Break
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2:30p
Strategies for Managing PFAS Leachate
A. For landfills collecting leachate
o What technologies are you using, considering, or heard of others using for
leachate containing PFAS? Please consider both monitoring and treatment
technologies.
B. Source management
o To what extent are landfills considering strategic handling of PFAS-
containing materials?
Wastewater Treatment and Leachate
o What strategies are wastewater treatment operators using to manage
leachate that may contain PFAS?
o How are wastewater treatment and landfill operators
coordinating/cooperating to more effectively manage leachate containing
PFAS?
3:30p
Strategies for Managing Landfill Capacity
A. Strategies for managing volume of PFAS-containing biosolids
o How does the presence of PFAS in biosolids change your volume reduction
approach?
B. Other
o In states where capacity is an acute issue (i.e., Northeastern US), what
conversations are wastewater operators and landfill operators having with
regard to accepting biosolids? Does this conversation play out differently in
other parts of the country?
4:30p
Adjourn
March 20th 1130a-430p E
11:30a
Communications: Messaging, Tools, and Strategies (Breakouts)
Prior to breakouts polling: Audiences and Communications needs
2 breakout groups. Each breakout will meet for 30 mins on each topic.
Breakout Round #1: Key Messaging
o What are key messages for the audiences and communication needs to
improve understanding of risk due to PFAS in municipal biosolids?
o What are the key messages for the audiences and communication needs to
improve public understanding of biosolids?
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Breakout Round #2: Tools/Strategies
o What tools or strategies does the biosolids community as a whole need to
most effectively reach their desired audiences?
o What specific tools or strategies do specific segments of the community
need (e.g., regulators, wastewater treatment operators, landfill operators,
etc.)?
Bp
Breakout Report Out
l:15p
Sampling and Monitoring Strategies
A. Approaches and Best Practices
o What challenges and successes have states/municipalities had in
establishing a sampling and monitoring approach?
¦ Experience with EPA Methods 1633 and 1621 and other methods
¦ Finding labs
¦ Cost
¦ Other
B. Incentivizing Sampling and Monitoring
o How do you align the incentives so that wastewater treatment operators,
landfill operators, and operators of incinerators voluntarily implement
sampling and monitoring strategies? How can communications support
this?
2:15p
Break
2:45p
Cost and Financing
A. Treatment
o What financing approaches or cost considerations could wastewater
treatment operators consider in pursuing solutions to better understand
concentrations and reduce PFAS in biosolids?
o What financing approaches could municipalities, states, and/or EPA take to
facilitate wastewater treatment operators to pursue solutions to better
understand concentrations and reduce PFAS in biosolids (e.g., financing
programs, partnerships, other?)?
B. Disposal or Beneficial Use
o What financing approaches or cost considerations could landfill operators,
incinerators, or land applicators consider, respectively, to manage the
challenge of PFAS in biosolids (e.g., understand concentrations, reduce PFAS
in biosolids, other?)?
3:45p
Engaging Other Stakeholders
• What can workshop participants do to support engaging other stakeholders?
4:15p
Wrap Up and Next Steps
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4:30p Adjourn
PFAS in Municipal Biosolids Workshop #3 Agenda
On May 29 -30, 2024, U.S. EPA's Office of Water convened a third in-person workshop to
discuss participants' individual feedback on the challenges and opportunities related to the
management of PFAS in biosolids. The workshop was held at the Environmental Council of the
States headquarters in Washington DC, and workshop participants represent state regulators,
wastewater and waste management regulated entities, and three EPA participants.
May 29th 9:00ai 0 pm
9:00 am Welcome, Get Settled, and Agenda Review (10 min)
9:10 am Scenario Breakouts: Round 1 (90 minutes)
Table top exercise in which participants will work through a scenario and actions that would be
taken in the event of a pre-determined PFAS level at a POTW. The participants will break into
two groups and work through the same scenario. The Facilitation Team will provide an
overview of the exercise prior to breaking into groups. Participants will have a short period of
time to read and think through the scenario prior to discussing as a group.
10:40 am Break (15 minutes)
10:55 am Breakout Report out and Discussion (60 minutes)
11:55 am Lightni s (20 minutes)
Two individuals will give a lightning talk for 10-14 minutes, and we will have 5-10 minutes for
questions.
12:15 pm Lunch (75 minutes)
1:30 pm Lightni s (25 minutes)
Three individuals will give a lightning talk for 15-20 minutes, and we will have 10-20 minutes for
questions.
1:55 pm Scenario Breakouts: Rou minutes)
This second scenario breakout session will follow the same format as the morning session, in
which groups will be presented with a scenario. Participants will break into group sand work
through the table top exercise.
3:00 pm Bre utes)
3:10 pm Breakout Report Out and Discussion (35 minutes)
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3:45 pm light™ s (25 minutes)
Three individuals will give a lightning talk for 15-20 minutes, and we will have 10-20 minutes for
questions.
4:10 pm Agenda De iview and Close Out
May 30th 8:30am - 12:30 pm
9:00 am Welcome, Get Settled, and Agenda Review (10 minutes)
9:10 am Communications Show and Tell (70 minutes)
Participants will present on a communications product their organization uses that they
particularly like and talk through what seems to work about it. Everyone will be encouraged to
share a product.
10:20 am Bre utes)
10:30 am Workshopping a Communications Product (90 minutes)
After the Facilitation Team provides directions, the group will self-select into 2-4 different
groups to talk through key messages, audiences, and dissemination tactics.
12:00 pm EPA Closing Remarks, Next Steps, and Meeting Close Out
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