PFAS Reportable Quantities Calculator for CERCLA Rule

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PFAS Reportable Quantities Calculator for CERCLA Rule
On September 6, 2022, EPA published in the Federal Register a proposal to designate PFOA and PFOS as hazardous substances under the Compre­hen­sive Envi­ron­men­tal Response, Compen­sa­tion, and Liability Act (CERCLA or Superfund). Under CERCLA, any release of a hazardous substance to the environment that exceeds its Reportable Quantity (RQ) is subject to specific reporting require­ments. For PFOA and PFOS, EPA has proposed an RQ of greater than or equal to one pound per 24 hours.
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This calculator is intended to help water reclamation facilities understand if their effluent discharges or biosolids management activities have the potential to trigger RQ require­ments. We have provided sample PFOA and PFOS concen­tra­tions based on preliminary data from a recent research project, but we encourage utilities to not rely on these average concen­tra­tions when making regulatory estimates. Using utility-specific data is highly recommended.

Plant Effluent

No RQ Detected!
No RQ Detected!

Biosolids

For sludge production, it is assumed that the annual production amount converted to average dry tons per day is an appropriate way to assess the RQ versus using any alternative processing or trucking schedules. While specific calcu­la­tions are not provided for sewage sludge incin­er­a­tors due to a lack of information on potential trans­for­ma­tion of PFAS during incin­er­a­tion, utilities processing their sludge through a sewage sludge incinerator can use the biosolids calculator as a conser­v­a­tive measure of whether the RQ may be an issue.

No RQ Detected!
No RQ Detected!
0.001 kilogram (kg)
1 gram (g)
1,000 milligram (mg)
1,000,000 microgram (µg)
1,000,000,000 nanogram (ng)
mg/L, mg/kg parts per million (ppm)
µg/L, ng/g parts per billion (ppb)
ng/L, ng/kg parts per trillion (ppt)
Location Units PFOA PFOS
Average 95%CI Average 95%CI
Effluent ng/L 10.43 3.20 9.42 4.18
Biosolids ng/kg 3,768 1,571 20,851 14,290
Source: WRF 5031 preliminary results of 38 WRRFs in 24 states
CI = confidence interval

CDM Smith and Trinnex do not warrant or assume any legal liability or respon­si­bil­ity for the accuracy, complete­ness or usefulness of information provided by, or obtained through the use of this tool. Users agree to use the tool at their sole risk, and to release and hold harmless CDM Smith and Trinnex from any and all liability with respect to their use of the tool.