From: Geoff Kuter Sent: Friday, July 19, 2019 3:26 PM To: Information, BWSC (DEP) Subject: Comments to amendments to MCP 310 CMR 40 Re; Comments to amendments to MCP 310 CMR 40 Mass DEP is proposing numerical limits for the total concentration of six PFAS compounds: PFDA, PFHoA, PFHxS, PFOA, PFOS, and PFNA. The GW-1 standard for these PFAS compound is set at 20 ppt. We believe that establishment of this limit at this value is not appropriate. At present there is a paucity of data on background soil levels and it is likely that the proposed limit may be at or below background levels. Furthermore, EPA has not yet established test methods for soils. We understand that DEP may feel the need to set limits but at this point there is a lack of good data on the distribution of PFAS compounds in soils in the Commonwealth and the movement of these compound through soils is not fully understood. Establishment of these limits will likely have the unintended consequences of discouraging the beneficial use of recycled materials including biosolids. Geoffrey Kuter, CEO Agresource Inc 110 Boxford Road Rowley MA01969 978-388-5110