Date
Monday, July 20, 2026
Time
2:00 PM - 2:30 PM
Location Name
Room 7, Level 2
Name
From Sludge to Strategy: Managing PFAS in Biosolids under Evolving Regulations
Track
Biosolids
Description
Per- and polyfluoroalkyl substances (PFAS) persist through conventional wastewater treatment and concentrate in biosolids, raising questions for utilities that beneficially reuse these materials on agricultural lands. Current federal policy is shifting on several fronts. EPA finalized the first PFAS National Primary Drinking Water Regulation in April 2024, adding enforceable limits for priority compounds which, while focused on finished water, is catalyzing upstream source control and wastewater-side monitoring programs that intersect with biosolids management. This presentation provides additional details on how these regulatory shifts impact biosolids planning and reuse.
On the solid-waste side, EPA’s 2024 update to its Interim Guidance on the Destruction and Disposal of PFAS outlines when incineration, landfilling, deep-well injection, and even interim storage may be appropriate, and provides new field-testing protocols for air emissions during thermal treatment. These recommendations emphasize site-specific evaluation and performance verification for technologies such as multiple-hearth or fluidized-bed systems, pyrolysis, gasification, and high-temperature oxidation. This session will highlight how these evolving recommendations inform technology selection and risk management.
In parallel, EPA designated PFOA and PFOS as hazardous substances under CERCLA in 2024, clarifying reporting obligations and sharpening liability considerations for releases, an action that can influence how utilities document handling, transportation, and end-use pathways for PFAS-bearing residuals. This presentation explores the compliance implications of this designation and strategies to address liability concerns.
EPA’s biosolids program continues to evaluate pollutants under 40 CFR Part 503 using multi-pathway risk assessment; PFAS are under active review within this framework, with program materials describing prioritization, screening, and refined risk analyses to inform any future rulemaking. Utilities should track this docket, as risk conclusions could translate into monitoring requirements or concentration-based ceilings for land application. This session provides updates on the program’s direction and its potential impacts on biosolids management practices.
Concurrently, multiple states are advancing policies that affect biosolids reuse without always naming PFAS outright, ranging from mandated PFAS monitoring and screening thresholds prior to land application, to conditional restrictions or moratoria, to constraints on sewage sludge incineration pending air-emissions verification. Sector briefs note a broader trend: precautionary state actions ahead of federal biosolids-specific PFAS limits, coupled with expectations for transparent public communication about risk and fate. Utilities should anticipate variability across jurisdictions and design programs that can meet the strictest plausible requirements. This presentation will review state-level trends and provide insights for utilities navigating a patchwork of policies.
Against this policy backdrop, a robust PFAS-in-biosolids strategy integrates: (1) influent/source control to reduce loadings; (2) routine PFAS monitoring of sludge streams with data management aligned to potential CERCLA reporting interfaces; (3) technology pilots that verify destruction performance and emissions control using EPA’s testing guidance; and (4) adaptive land-application or disposal plans with clear public messaging on benefits, safeguards, and contingencies. Such a framework positions utilities to maintain beneficial reuse where feasible, pivot to destruction pathways when required, and stay compliant as federal and state policies continue to evolve. This session concludes by presenting actionable strategies and case examples to help utilities develop resilient, forward-looking biosolids programs.
Speakers