Date: November 7, 2022
Venue: Environmental Protection Agency
Proceeding: Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances
EPSA explains that power generators do not typically use or create PFOA or PFOS as part of their operating processes. However, generators may maintain firefighting equipment, some of which includes firefighting aqueous film forming foam (AFFF) solutions, to respond to fire emergencies. PFOA and PFOS are often present in AFFF, whether as an intended ingredient or a side product in manufacturing AFFF. EPSA requests that the EPA differentiate this type of use to protect life safety in limited circumstances and thus exempt properly applied AFF from CERCLA’s release reporting and cleanup requirements.