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Petition from Berkeley Law School to Designate Wastes with PFOA Etc as Hazardous Waste under RCRA Subtitle C

The petitioners request that EPA promulgate regulations designating wastes containing PFOA (perfluorooctanoic acid), PFOS (perfluorooctane sulfonic acid), GenX chemicals, and any combination of these, as hazardous waste subject to the management and disposal requirements of Subtitle C of RCRA. Petitioners also request that the RCRA hazardous waste designations for PFOA and PFOS wastes extend to cover the full chemical subclass of each—long-chain perfluoroalkyl carboxylates (LCPFACs) and long-chain perfluoroalkane sulfonates (LCPFASs), respectively.

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Petition from Berkeley Law School to Designate Wastes with PFOA Etc as Hazardous Waste under RCRA Subtitle C (PDF)(27 pp, 430 K)