Reporting TURA Certain PFAS NOL: What you need to know
This webinar discusses this new category of reportable chemicals under the Toxics Use Reduction Act, Certain PFAS Not Otherwise Listed (NOL) and offers guidance to toxics use reduction planners on how to determine if you are using products containing PFAS and how to estimate those uses. Guidance from MassDEP is also offered.
Please note: We'd like to amend an answer given during the webinar regarding AFFF present in fire suppression systems. EPA does require reporting of releases of AFFF from a facility fire suppression system and TURA will also follow this guidance: https://ordspub.epa.gov/ords/guideme_ext/f?p=GUIDEME:GD:::::gd:pfas_resources_2_7
Additionally, as a follow up to the question on PFAS present in incoming process water, EPA offers the following answer for a question about lead in process water, which TURA will also follow for PFAS in this circumstance: Q329. A facility uses river water as process water. The water taken from the river contains more lead (1.0 ppb) than the water returned to the river (0.5 ppb). Is it eligible for the process water exemption? If not, is the facility treating the water? The process water can be considered exempt because the listed toxic chemical was present as drawn from the environment (40 CFR Section 372.38(c)(5)). The facility does not need to consider lead in the process water for threshold or release and other waste management reporting.