New Mexico Environment Department Request for Information: Scientific Findings/Available Technology Related to PFAS-Contaminated Livestock/Disposal and/or Destruction of PFAS

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The New Mexico Environment Department (“NMED”) issued a May 19th Request for Information (“RFI”) addressing:

Scientific Findings and Available Technology Related to PFAS-Contaminated Livestock and Disposal and/or Destruction of PFAS

NMED is seeking information related to:

  • PFAS disposal and/or destruction across various forms, sectors and media
  • Data specific to individual PFAS compounds/classes of PFAS
  • Relevant scientific studies, technology testing, policy considerations and active research projects

PFAS have been used in various industrial applications and consumer products such as:

  • Fabrics for furniture
  • Paper packaging for food and other materials resistant to water, grease or stains
  • Firefighting at airfields
  • Utilization in several industrial processes

They have been described as persistent in the environment and resist degradation.

The RFI identifies what it deems as relevant information such as:

  • PFAS-contaminated livestock, including any information on bioconcentration, products of metabolism, strategies to reduce PFAS concentrations in animal tissue and plasma, etc.
  • Composting PFAS-contaminated livestock carcasses, including the composting method and resulting concentrations of PFAS compounds in the compost.
  • PFAS destruction, including methodology and efficacy data.
  • Incineration of PFAS-contaminated material, including:
    • By-products (e.g., dioxins/furans) and PFAS residuals,
    • Air emissions associated incineration,
    • Fate and transport of PFAS during incineration, and
    • Subsequent disposal of solid material (e.g., ash) in a landfill.
  • Data from placing PFAS-contaminated material in a hazardous waste landfill or associated research into short- and long-term risks.
  • Related to the above topics:
    • Technology testing,
    • Research studies, and
    • Case studies or pilot projects

In the “Background” section of the RFI it is noted that PFAS-contamination in groundwater related to the U.S. Department of Defense at Cannon Air Force Base resulted in contaminated livestock at the Highland Dairy. Highland Dairy has apparently prepared a two-phase removal plan addressing contaminated livestock. It is described as the first of its kind and the development it was developed in consultation with the:

  • Farm Service Agency
  • USDA NRCS
  • State Veterinarian of New Mexico
  • New Mexico Department of Agriculture
  • NMED

The RFI states that information it collects will:

. . . support strong policy and science-based decision-making during implementation of Phase 2 of the Removal Plan.

A copy of the RFI can be downloaded here.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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