Anonymous public comment

This comment is for Docket No. EPA-HQ-OLEM-2020-0527 associated with the Interim PFAS Destruction and Disposal Guidance (Interim Guidance) I urge for a revision of the Interim Guidance to recommend human health and ecological health risk assessments for PFAS destruction and disposal methods. Evaluating the potential human health and ecological risks as a result of implementing a destruction or disposal method is an essential component of the method. Some methods, such as thermal treatment, may create gaseous or vapor forming PFAS chemicals during the destruction processes which may result in the creation of new exposure pathways. Potential risk, hazard, and novel exposure pathways will impact communities in the short and long term, and evaluation of potential risk and hazard should be evaluated as a core component of the decision making process for PFAS destruction or disposal methods. The lack of discussion regarding human health or ecological risk assessments is concerning, especially when coupled with the potential deregulation for select PFAS under the Safe Drinking Water Act and PFAS National Primary Drinking Water Regulations. PFOA and PFOS are known carcinogens, and the lack of consideration given to address health implications as a result of destruction and disposal technologies is counterproductive to the intentions of the Interim Guidance. Additionally, I urge all references to the “Department of War” be named according to the current, formal legal name, “Department of Defense”. Executive Order 14347 does not replace or supersede law or Congressional approval required to formally rename the Department.