PPRC Position Paper on Per- and Polyfluorinated Alkyl Substances
Beneficial Use of Mill Residuals and Listing of PFOA and PFOS as CERCLA Hazardous Substances
The PPRC asks EPA to recognize and support the safe and beneficial use of mill residuals.
- In the papermaking process, a large portion of mill residuals generated are composed of tree fiber (cellulose). PFOA and PFOS are widespread in the environment, and detection limits are extremely low, so they sometimes can be detected in residuals, albeit lower than the background levels found in common house dust.
- These residuals are often used beneficially as soil amendments for agricultural or forest lands. They can reduce soil erosion, reduce the need for irrigation, increase soil nutrient-holding capacity, and reduce soil compaction, which improves plant growth.
- The PPRC is concerned that the listing of PFOA and PFOS as hazardous substances under CERCLA (Comprehensive Environmental Response, Compensation and Liability Act), the Superfund law, could have the unintended outcome of impeding or preventing the safe and beneficial use of paper mill residuals as soil amendments.
- The paper industry stopped using long-chain PFAS over a decade ago, so we are not a source of new loadings into the environment.
- The PPRC would like EPA to recognize the safe and beneficial use of mill residuals as soil amendments. The CERCLA regulation should include a provision stating that the land application of paper mill residuals falls within the scope of the “normal application of fertilizer” exclusion from CERCLA whenever the concentrations of PFOA and PFOS in such residuals are comparable to the levels found in conventional fertilizers and soil conditioners. This is modeled on EPA’s position, since 1993, regarding land application of municipal biosolids as fertilizer or soil conditioner.
- We strongly recommend that EPA exclude the beneficial and safe use of soil amendments from paper mills from the CERCLA listing. Specifically, CERCLA provides four exclusions for the use of a designated listing, including the normal application of fertilizer. Additionally, EPA interpreted the normal application of fertilizer exclusion to encompass application of biosolids as a fertilizer substitute or soil conditioner. Paper mill residuals are used as fertilizer substitutes and soil conditioners, and PFOA and PFOS incidentally contained in these residuals should be excluded from this rule.