PFAS in the Waste Stream: Mass Balance Accounting and Extended Producer Responsibility

PFAS in the Waste Stream: Mass Balance Accounting

and Extended Producer Responsibility

Prepared for: Kim Crosby, Environmental Compliance Manager and Samuel C. Nicolai, PE, Vice President of Engineering & Compliance, Casella Waste Systems, Inc.

Prepared by: Helena Milazzo, Erin Hogan, Tyler DeShong, Kevin Brito Middlebury College Environmental Studies Community-Engaged Practicum

May 2021

Table of Contents

Project Background/ Introduction 2 Methods 4 Literature Review, Case Studies, and Additional Research 4 Community Interviews and Public Comments 4 Data, Data Gaps, and Assumptions 5 Results 7 Sanborn, Head, and Associates Report 7 10 Comparative U.S. and Australia Case Study 11 Food Packaging/ Manufacturing Study 14 2019 Vermont Materials Management Plan and 2021 Biennial Reports 14 Community Interviews and Public Comments 16 Discussion 17 Recommendations and Solutions 18 Middlebury Upcycling Campaign 19 Further Research 21 Conclusion 22 Acknowledgements 23 Bibliography 24 Appendix 27

1 Project Background/ Introduction

For decades, the United States has grappled with the toxic presence of per- and polyfluoroalkyl substances (PFAS) at every stage of the product life cycle; in production factories, in surface and groundwater, and ultimately in the human body. Over the years, different types of PFAS have been developed and popularized—from the older generation of long-chain PFOA and PFOS, to their short-chain counterparts like GenX. These short-chain successors perform the core functions desired of all PFAS but are better able to evade municipal and commercial efforts to remove and sequester them. This includes efforts from the waste management sector (Lang et al., 2017).

All PFAS, regardless of age, are a pressing environmental health concern (Sunderland et al., 2019). Though production phaseouts of PFOA and PFOS are regulatory success stories, their legacy remains in the environment due to their persistence. This is a problem which waste management faces first hand, since PFAS products of all ages and from all waste streams are continuously dumped in landfills everywhere. The presence of PFAS in landfills poses a threat to communities as landfills play a critical role in the long-term sequestration of hazardous materials. The capacity for landfills to, in fact, sequester PFAS is jeopardized by the availability of space and the rate of PFAS influx, both of which can affect leachate quality (EWG Science Investigation Team, 2020). The long-term viability of sending PFAS-leaching products to landfills is called into question, as the idea of extended producer responsibility (EPR) gains traction with an increasingly conscious public. Additionally, as legislators around the country continue to prioritize PFAS regulation, policymakers can better oversee PFAS manufacturing and uncover the historically misunderstood practices of irresponsible chemical manufacturers (VPIRG, 2021).

Most contemporary PFAS governance concerns itself with regulating the chemical production stage, and not the environmental leaching/pollution stage. It is important to understand the role that waste management will need to play in the product end-of-life plan for the various waste streams that contribute to PFAS in landfills. Because individuals, as well as commercial, industrial, and municipal entities dispose of PFAS-containing products in landfills, the waste management sector must have a multi-pronged approach that aims to improve stakeholder engagement and community awareness of the PFAS problem. Toxic PFAS products can have as much as a decadal-scale time lag between consumption and disposal, particularly regarding products like textiles, carpets, and mattresses (Gallen et al., 2017). Part of the regulatory process must directly address the PFAS products in circulation today—which will not enter the waste stream for years to come—as well as those currently at the end of their product life and approaching disposal.

Our community partner, Casella Waste Systems, Inc., has been making a concerted effort to research and understand PFAS in the waste stream at their landfill in Coventry, Vermont—the sole landfill in the state. With environmental consultants at Sanborn, Head and Associates (SHA), ‘waste resource testing’ was conducted in 2019 to determine the daily concentration of PFAS entering the landfill via different product categories (“waste streams”), also called mass flux. A variety of municipal, commercial, and industrial waste streams were tested for PFAS,

2 including, most notably: bulky items (i.e., furniture), carpeting, textiles, wastewater treatment plant (WWTP) sludge, and commercial consumer items (i.e., food packaging).

To build upon this waste resource testing, our team used existing information to determine how Vermont’s current (and developing) PFAS regulation scheme is affecting waste management. Specifically, Casella is looking for ways to divert PFAS waste through efforts including EPR and waste repurposing or refurbishment (see Discussion- Middlebury Upcycling Campaign). First, we investigated Casella’s mass flux data using 1) research into PFAS monitoring/regulation at the state, regional, national, and international level, as well as 2) community outreach to better understand local attitudes on curbing PFAS pollution. Because SHA’s waste resource testing is the first of its kind in the U.S., it is important to pull from existing (even if tangential) research, in order to determine if Casella’s efforts and findings track with the larger hazardous chemical waste management framework. Our team identified several states, including Connecticut and Delaware, for data contextualization and comparison.

Because waste management is a public service, and landfills receive waste from a diffuse number of parties, Casella cannot be expected to bear the financial brunt of PFAS remediation efforts. As such, diverting PFAS waste from the Coventry waste stream is a logical piece of the puzzle. Our team’s investigation into waste diversion tactics provide a framework for Casella to share the burden of PFAS sequestration equitably with other complicit actors—namely manufacturers and consumers. We have identified several paths forward—that would, importantly, involve government, corporate, and community grassroots intervention—including the establishment of recycling/compost facilities, manufacturer disposal programs (for textiles, carpet, mattresses, etc.), and upcycling appropriate materials.

Lastly, our team makes recommendations to Casella regarding appropriate metrics for measuring PFAS concentrations in different waste streams entering the landfill either directly or via waste transfer stations. These recommendations aim to refine the sampling methods used in Casella’s waste resource testing to ensure that future testing captures all possible PFAS sources and reflects total concentrations as accurately as possible. Nuances in waste resource testing are becoming increasingly important as the patchwork phaseout of PFAS now means that whole waste streams, such as food packaging, cannot be totally counted or discounted as point sources of PFAS. Food packaging, for example, is increasingly becoming a waste stream with a mix of PFAS and PFAS-free materials depending on the company they come from (Cabrera, 2021; Dickman et al., 2020). In summary, this project has been shaped as a consultant report that integrates Casella’s operating plans for the future with as many of its community stakeholders as possible.

3 Methods

Literature Review, Case Studies, and Additional Research The literature review focused primarily on contextualizing the 2019 Waste Source Testing Report conducted by SHA contracted by Casella Waste Systems (Sanborn, Head & Associates, Inc., 2019a). The SHA report was conducted as a result of growing concerns over PFAS in the waste stream and, as Vermont’s sole landfill operator, Casella sought this report to better understand the mass flux of these substances in their Coventry site. This review has been broken down into two main parts: the examination of the SHA 2019 Waste Source Testing Report to understand the existing data, and the in-depth examination of further governmental waste breakdown reports such as the 2013 Vermont DEC Waste Composition and 2018 Vermont DEC Waste Characterization Reports to analyze the accuracy of data representation in the SHA Report (See Appendix) (MidAtlantic Solid Waste Consultants & DSM Environmental Services, 2013; DSM Environmental Services, 2018).

Additionally, we researched two waste characterization case studies, one conducted in Australia and another conducted in the continental United States covering California, Delaware, Georgia, Iowa, Kansas, Minnesota, Missouri, Oregon, Pennsylvania and Wisconsin (Gallen et al., 2017; Staley & Barlaz, 2009). These studies help to contextualize the survey data from the SHA report on both a national and international scale. This allows us to identify components of the Vermont waste stream that are unique—including the state’s economic and legislative structures that contribute to that uniqueness—and also to study alternative survey methods to more critically examine the assumptions made during the SHA surveying process.

In addition to contextualizing the provided data, we provide recommendations to expand sampling in the municipal solid waste management industry. Further manufacturing-specific research on products like food packaging as well as additional Vermont DEC reports, like the 2019 Municipal Management Plan and the 2021 Biennial Report on Solid Waste, have been conducted to examine possible strategies for PFAS monitoring in the waste stream (Vermont Agency of Natural Resources, 2019; Vermont Agency of Natural Resources, 2021). These reports were also used to determine the viability of utilizing existing waste management legislation to focus specifically on PFAS mitigation such as Vermont’s Extended Producer Responsibility (EPR) laws and Vermont’s Universal Recycling Law (See Appendix) (Vermont Agency of Natural Resources, DEC, 2021; Vermont Agency of Natural Resources, n.d.). These studies also led our group to investigate community engagement and education programs to begin PFAS management at a product’s midstream—understood as the post-purchase, pre- disposal part of a product’s life cycle—rather than focusing solely on retroactive solutions.

Community Interviews and Public Comments In addition to case study research and state-specific management plans, we also conducted an interview with Martin Wolf, director of authenticity and sustainability at Seventh Generation, and attended the Toxics in Packaging Clearinghouse (TPCH) 2021 Model Legislation Update Webinar hosted by John Gilkeson, of the Minnesota Pollution Control

4 Agency and Chair of TPCH, to better understand how legislation is affecting current PFAS restrictions in specific states and companies (Gilkeson, 2021). Holding a senior level-position at Seventh Generation which manufactures eco-friendly cleaning and personal-care items, Martin Wolf described the company’s ongoing management of chemicals, including PFAS, and their waste disposal practices at the production level. The TPCH webinar outlined the efforts to control the introduction of certain chemicals to packaging via the Model Toxics in Packaging Law at the local, state, and federal levels which initially covered four specific elements but has been amended to include PFAS in 2020 (See Appendix). The information collected during these sessions has been utilized to inform our recommendations and solutions about legislative restrictions and their effectiveness in modifying the waste stream.

To help inform our recommendations surrounding community engagement, we utilized the “Report Responsiveness Summary to Comments on the 2021 Biennial Report on Solid Waste.” This document outlined the comments from the Lamoille Regional Solid Waste Management District and the Conservation Law Foundation and their associated responses from the Vermont Agency of Natural Resources (ANR) (See Appendix) (Vermont Agency of Natural Resources, 2020). We utilized this document to gage the Vermont community responsiveness and knowledge towards the 2021 Solid Waste Report and also to highlight the shortcomings of the report and use those acknowledged areas to inform our further research and recommendations.

Additionally, we sought local community members to interview regarding their disposal practices and specific interactions with PFAS-containing materials. A post was generated for Front Porch Forum, a self-selecting community engagement tool, which drew a varied group of interested individuals (see Discussion- Middlebury Upcycling Campaign).

Data, Data Gaps, and Assumptions Though the SHA report was integral to our continuing study, we must acknowledge the assumptions built into their research (Sanborn, Head & Associates, Inc., 2019). It is important to understand these assumptions to gauge their implications, as well as the reliability of any recommendations that directly build off of them. The purpose of naming them is not to critique, but rather to recognize their importance and acknowledge them in future iterations of waste resource testing. Some of the most important assumptions are as follows:

Waste disposal rates

Each class of waste (and PFAS concentrations in each class of waste) was presented as contributing to a daily rate of mass flux, for ease of comparison across waste types in the report.

Waste disposal composition

Not all types of waste that enter Casella’s landfill were considered in the report, just those ‘likely’ or ‘known to’ contain PFAS. Notably, Municipal Solid Waste (MSW) from residential sources was not included in waste testing.

5 Small sample size limitations

As is often the case with studies of this nature, the samples taken in this study were assumed to be representative of all waste types entering the landfill; as well as representative of all PFAS sources contributing to landfill leachate.

Sources and sinks of PFAS mass flux

PFAS mass flux was only considered to contribute to Casella’s landfill leachate, and any concentrations of PFAS in the air or in landfill gas were considered negligible.

Mass of PFAS in textiles/bulky items

A textile mass of 10% (10% of the object’s mass) was assumed for all furniture and other bulky items, such as couches. The other 90% was considered to have negligible PFAS.

Carpet and carpet padding

Carpet padding was assumed to contain negligible PFAS, while the carpet itself was to account for all PFAS concentrations in this class of waste. Importantly, a 2-to-1 mass ratio of carpet-to-carpet padding was assumed for calculating PFAS masses in carpet.

6 Results

Sanborn, Head, and Associates Report

As the central figure of analysis for this project, the SHA report of the New England Waste Services of Vermont (NEWSVT) landfill investigated over 100 samples from incoming waste at their Coventry location. They had identified seven specific waste streams that, based on previous research, were assumed to contain notable concentrations of PFAS. These waste streams are industrial and WWTP sludge, sewer grit, contaminated soil, bulky waste items including carpeting and textiles, construction and demolition (C&D) waste, and commercial customer waste, e.g., items like food packaging. Of these samples, PFAS were found in 95 percent with concentrations ranging from approximately 2000 ppb in specific bulky items to less than 0.5 ppb in certain C&D materials (Fig. 1). On average, textiles and carpeting were found to have the highest concentration of PFAS while contaminated soil, C&D and commercial customer wastes were found to contain the lowest concentrations, nearly all of which contained less than 0.5 ppb (Sanborn, Head & Associates, 2019, p. 15).

Figure 1. Average and Maximum Total PFAS Concentration by Waste Type. Figure sourced from Sanborn, Head & Associates, NEWSVT PFAS Source Testing (2019). pp 2.

Additionally, Sanborn, Head and Associates utilized their mass flux data to create a visual comparison between PFAS input and leachate output (Fig. 2). This comparison highlighted a mass imbalance between the PFAS streams entering the landfill and the PFAS exiting, finding that a very small portion of the chemicals are exiting the landfill via leachate (Sanborn, Head & Associates, 2019, p. 3). While this may be a result of the effectiveness of the Coventry site’s sequestration and containment, it may also be that PFAS is leaving the landfill through other modes of transport. Overall, this report provided a baseline of PFAS concentration within the Coventry landfill as well as provided insight into sampling methods and assumptions that can be fine-tuned (see Discussion).

7 Figure 2. Estimated Total PFAS Mass Flux In and Out of the Landfill. Figure sourced from Sanborn, Head & Associates, NEWSVT PFAS Source Testing (2019). pp 3.

Table 1. Comparison of Vermont’s Current Residential and ICI 2013-2018 Waste Characterization MSW Composition to Past Studies. Table sourced from DSM Reports Environmental Services, 2018 Vermont Waste Characterization. (2018). pp 35 Despite managing the sole landfill in Vermont, Casella does not process the entirety of the state’s waste. About 100,000 tons out of nearly 500,000 tons of waste are sourced in Vermont but sent to facilities in New York, New Hampshire, and Massachusetts (Waste Management & Prevention Division & Solid Waste Management Program, 2020). Thus, we sought to situate the Sanborn, Head & Associates report on a comprehensive Vermont scale as well as contextualize it within a broader national stage through an in-depth analysis of the Vermont Department of Conservation 2018 Waste Characterization Report. The data collected during the surveying took place at multiple transfer stations throughout the state and categorized the waste into four separate groups which consisted of residential MSW (Mixed Solid Waste), industrial/ commercial/ institutional (ICI) MSW, construction and development waste, and bulky waste (Residential and ICI). The residential and ICI MSW groupings were broken down into multiple categories and

8 subcategories, and bulky wastes and C&D wastes were divided into separate but equally as meticulous categories. Using hand-sorting and weighing methods, overall tons of waste in each category and subcategory were estimated. Both residential and ICI MSW exhibited similar high percentages of organics, paper and special/other (which contains things like textiles and carpets), respectively (Table 1). While these findings suggest that SHA’s decision to focus on specific streams like carpets and textiles was warranted in the sheer amount of these products entering the landfills, it also highlights the limitation in excluding residential waste which Table 2. Comparison of Vermont MSW to Delaware, Rhode comprised about 11,000 more tons of waste Island and Connecticut. Table sourced from DSM than ICI (DSM Environmental Services., Environmental Services, 2018 Vermont Waste. 2018). Characterization (2018). pp 33 Utilizing the data highlighted above, the report compared findings to those found in previous years (Table 1). Most significantly, this comparison highlighted the reduction in disposed recyclables since 2002. Additionally, the report compared Vermont’s 2018 data to studies that had been conducted in Delaware, Rhode Island, and Connecticut to determine the uniqueness of the Vermont waste streams. Based on this comparison, Vermont had similar waste composition to these other northeastern states (Table 2). Finally, the report aggregated the various Vermont data to create a state-wide waste composition dataset (Table 3). ICI and Residential MSW were combined along with a small percentage of removed bulky waste to exemplify the overall MSW disposed of in Vermont. These results show a higher tonnage value for the special/other category which includes a significant amount of the highly concentrated PFAS items like carpets and textiles (DSM Environmental Services., 2018). Acknowledging that not all of Vermont’s waste is processed in the state, this review of the 2018 Waste Characterization report was necessary to situate Vermont in a regional context, assisting in the determination of Vermont’s uniqueness, as well as aggregating the measured waste streams for a holistic view of the state which allowed for greater analysis into the assumptions used during the sampling. Additionally, this study highlighted significant changes that have occurred in the Vermont waste stream overtime supporting the possibility of diversion methods (see Discussion).

9 Table 3. Aggregate of MSW Disposed. Table sourced from DSM Environmental Services, 2018 Vermont Waste Characterization (2018). pp 17.

10 Comparative U.S. and Australia Case Study U.S. A U.S. case study compiled by Bryan F. Staley and Morton A. Barlaz constituted 11 independent, state-conducted waste characterization surveys and the national Environmental Protection Agency (EPA) survey. The data were recompiled into the tables presented below with particular emphasis on overall Mixed/ Municipal Solid Waste (MSW) mass discarded and the differences between the discarded and landfilled rates (Table 4) (Staley & Barlaz, 2009, p. 904). Also included is the percentage of specific waste stream components that were identified in the SHA report as significant PFAS contributors and are large contributors by mass to the Vermont landfill (Table 5) (Staley & Barlaz, 2009, p. 906). While not part of this particular survey, Vermont data has been compiled and included at the bottom of Table 4 and the end of Table 5 for comparison that will be discussed in a later section.

Table 4. Discard MSW Masses, Discard Rates.

Discarded Landfilled MSW mass Population MSW Rate MSW Rate Entity Study Year discarded (thousand (thousands) (kg per person per (kg per person per Mg per year) day) day)

U.S. EPA 2006 299,398 157,170 1.44 1.15

California (CA) 2003 35,377 27,967 2.17 2.11

Delaware (DE) 2006 853 784 2.52 2.52

Florida (FL) 2000 15,982 12,395 2.12 1.66

Georgia (GA) 2005 9,108 5,834 1.76 1.73

Iowa (IA) 2005 2,956 1,612 1.49 1.46

Kansas (KS) 2001 2,701 2,363 2.40 2.39

Minnesota (MN) 2000 4,919 2,788 1.55 0.94

Missouri (MO) 1998 5,439 2,501 1.26 1.25

Oregon (OR) 2002 3,522 2,018 1.57 1.43

Pennsylvania (PA) 2001 12,288 7,489 1.67 1.26

Wisconsin (WI) 2001 5,409 3,039 1.54 1.48

Vermont (VT) 2017 624 422 N/A 1.48

Table 5. Discarded MSW Stream composition Comparable to VT (% by Wet Mass).

Waste Component EPA CA DE FL GA IA KS MN MO OR PA WI VT

Textiles 4.2 3.1 3.3 4.6 4.2 5.9 11.0 2.8 N/A 3.8 4.3 3.5 4.2

Food Waste 17.7 19.0 12.1 9.7 12.6 12.7 9.5 12.8 N/A 19.4 13.7 14.5 12.1

Carpet 1.6 2.7 2.1 N/A 1.5 N/A N/A 2.8 0.9 2.5 2.0 3.9 3.1

Bulky Items 9.6 7.7 1.8 N/A N/A 3.2 N/A 3.5 2.2 1.6 1.4 3.7 9.1

Australia

A nationwide assessment of PFAS entering landfills in Australia shows that the waste management of PFAS is a global concern (Gallen et al., 2017). This study on PFAS concentrations in landfill leachate was conducted at a coarser resolution than SHA’s waste resource testing (3 waste streams in the Australian study versus 7 in the SHA report). The three waste streams studied were MSW, C&D, and commercial and industrial (C&I) waste. Nevertheless, the overlap in their methods and findings does bolster the work that Casella is doing on their own. Gallen et al. 2017 found that shorter chain PFAS, including PFHxA, PFHxS, and PFHpA were within the top 5 most prevalent PFAS in Australian landfills, along with PFOA and PFOS (Fig.3). Similarly, Sanborn Head concluded that PFHxA, PFHxS, and PFHpA were greatly magnified in landfill leachate compared to the product sample from which the leachate was sourced (Fig. 4) (Sanborn, Head & Associates, Inc., 2019).

Figure 3. From Gallen et al. PFAS concentrations across 27 Australian landfills. Note the prevalence of PFHxA, PFHxS, and PFHpA (along with PFOA and PFOS) in nearly all samples.

Figure 4. From Sanborn Head & Associates, Inc. Showing the comparison of PFAS content in waste sample leachate with its potential precipitate content in SPLP testing. What is important to note is that PFHxA, PFHxS, and PFHpA are magnified in concentrations through the SPLP method in 5 of the 11 samples. From NEWSVT PFAS Source Testing (2019).

Gallen et al. 2017 additionally noted that landfills accepting majority C&D waste (>50% of accepted waste) had higher average PFAS concentrations, for all PFAS measured in the study, than landfills accepting majority MSW. Nonetheless, the authors also identified textiles and carpet from MSW landfills as significant contributors to PFAS leachate. This is considered to be consistent with Casella’s identification of carpets and bulky items as the greatest potential contributors to PFAS in landfill leachate. Additionally, in seeing that carpet is also reasonably associated with C&D waste materials, as are bulky items, these findings confirm the PFAS- priority waste streams that Casella was able to identify in their landfill; though, because waste classification can sometimes be murky (such that a particular item entering the landfill could be classified into more than one category), these findings are potentially subjective.

A final key takeaway from the Australian study is that PFAS-containing effluent from landfill sites is comparatively minor in the context of PFAS effluent from other sources, such as wastewater treatment plants (WWTPs). In the treatment process at WWTPs, the authors confirmed that PFAS precursors can more effectively break down and be released into the environment. This puts into context the findings from the Sanborn, Head and Associates report that only an extremely minor amount of PFAS is leaving the Coventry landfill, and that largely Casella’s Vermont site is successfully sequestering PFAS.

13 Food Packaging/ Manufacturing Study In 1960 the FDA authorized several broad classes of PFAS for use in food packaging due to their non-stick as well as grease and oil resistant properties. These broad classes fall into four main categories. The first of these categories is cookware. PFAS is frequently found in the coating used to make cookware non-stick. Secondly, gaskets, O-rings and other food processing equipment often use PFAS as a resin (FDA 2020). Thirdly, PFAS is utilized in processing aids through its use in the manufacturing of other food contact polymers. This in turn reduces build up on equipment. Lastly, PFAS is present in paper/paperboard food packaging. PFAS is often used as a grease-proofing agent in fast-food wrappers, microwave popcorn bags, take-out paperboard containers, and pet food bags. Evidently, food packaging is a large contributor to PFAS in our waste stream (Sanborn, Head & Associates, Inc.). In 2016 the FDA revoked the regulations that authorized the use of long-chain PFAS in food packaging (FDA, 2020). As of November 2016, long-chain PFAS are no longer used in food packaging in the United States (FDA 2020). Since then, 3 manufacturers, in 2020, have voluntarily committed to a three-year phase out of short-chain PFAS in food packaging (FDA, 2020).

There are many upcoming PFAS free food packaging alternatives. A majority of the alternatives are made from bamboo. One example is Bambu® which manufactures disposable plates and bowls from thin sheets of bamboo. New York, Maine, and Washington, as well as cities like San Francisco and Berkeley, CA have banned the use of PFAS in their packaging and to-go containers (NY, CA, Maine, WA.gov, 2019). These steps will only ensure that PFAS are not only kept out of our landfills but also our food, water, and bodies.

2019 Vermont Materials Management Plan and 2021 Biennial Reports The 2019 Vermont Materials Management Plan’s (MMP) purpose is to provide a framework for 1) waste reduction and prevention in Vermont communities, 2) extend the longevity of already manufactured items, and 3) instill proper disposal practices for these items down the line using methods such as recycling and composting (VT MMP, 2019). Our group explored areas of this document to determine the efforts Vermont has made to reduce the disposal of items of interest such as C&D and textiles.

Due to the lack of convenient and cost-effective C&D disposal /recycling facilities in the area, recycling of these items is inhibited even though they make up a significant portion of the waste stream. As of 2017, 85,234 tons of C&D materials were sent to landfill, and 12,036 tons were diverted for recycling. MMP notes that the catalyst for lack of recycling is likely proximity of C&D sites to appropriate recycling facilities (VT MMP, 2019).

A 2015 study demonstrated that Vermont has been losing accessibility to convenient textile collection locations, particularly in rural areas (VT MMP, 2019). However, since 2014 the tons of textiles diverted from the landfill has increased and as of 2017, 369.6 tons had been prevented from entering the landfill. To continue this trend, Solid Waste Management Entities

14 (SWMEs) are annually checking that there is at least a single textile collection location within each region in Vermont to ensure community members have an accessible option for clothing donation and recycling.

In response to the Vermont Materials Management Plan, the Vermont ANR released a biennial report as current status update of waste management in the state. The 2021 Biennial Report on Solid Waste has highlighted the effects that major legislation, as suggested in the MMP, has had on the various waste streams in Vermont (Vermont Agency of Natural Resources, 2021b). A summary of those laws is outlined below in Table 6.

Table 6. A composite table outlining the effects of major legislative action on Vermont waste streams.

Programs and Description Effects Legislation

First Implemented in 2014, in the - Disposal of Food years since this law has effectively Scraps banned on July 1, banned specific plastics, glass and 2020. Universal Recycling paper (blue bin recyclables), leaf and - 10% increase in (UR) Law yard debris, and food scraps recycling since 2014 (compostables). - 72% of mandated recyclables were diverted from the landfills

Targeted bans on single-use products - Banned the use of like straws, stirrers, foam containers, plastic bags and Single-Use Products and plastic bags. Also, ANR is instituted a small fee on (SUP) Law seeking to introduce a SUP Working paper bags on July 1, group. 2020

A deposit (between 5 and 15 cents) is - 75% of eligible added to the price of specific containers are claimed containers which can be redeemed - Non-collected deposits Bottle Bill when those containers are returned to are donated to the Clean specific recollection centers. Water Fund (over $2,000,000 to date)

This program is focused on extended - Vermont leads the product life-cycle responsibility to country in per capita consumers and producers through recycling for electronics, Extended Producer special collection systems thus paint, batteries, and other Responsibility (EPR) lowering the overall MSW disposed. mercury products This is meant to reduce both the - Recycling increased financial and environmental impacts for batteries by 14% and on municipalities. for paint by 4% in 2019

15 According to these current updates, there must be increased efforts within Vermont to achieve the goals introduced in the 2019 MMP. The goals, including a 10% reduction in waste generation, 50% recycling/composting rate and a 25% decrease in total MSW disposal by 2025, are growing more difficult to achieve as the per capita waste disposal rate has increased 8% since 2014 and the diversion rate remains at about 35% (Vermont Agency of Natural Resources, 2019).

Community Interviews and Public Comments

In the 2021 Report Responsiveness Summary To Comments on the Biennial Report on Solid Waste, the Lamoille Regional Solid Waste Management District and the Conservation Law Foundation left comments on the initial reporting questioning some discrepancies they had found in addition to addressing some of the claims made by the ANR (Vermont Agency of Natural Resources, 2020) . In the report, the commenters challenged the ANR’s use of “great” when referring to the recycling rate in the state of Vermont and questioned how the 72% recovery rate that was reported compared to other studies on a regional and national level. The contracted waste characterization report was conducted by the company DSM which had reported that similar waste studies they had conducted (as mentioned in the 2018 Waste Characterization Report above) produced a recycling rate between 50-80% (Vermont Agency of Natural Resources, 2020). This gave insight into not only Vermont’s community awareness of waste management, which informed our community engagement efforts, but also indicated that certain aspects of Vermont's waste stream are similar to other, nearby states which will support some of our recommendations and solutions (see Discussion).

In searching for industry professionals to interview, we were fortunate to be able to speak with Martin Wolf of Seventh Generation. This eco-friendly cleaning and personal care product brand has always upheld strict toxic material regulations beginning at the inception of the company in 1988. Seventh Generation continues to restrict the use of known hazardous chemicals such as carcinogens and immunosuppressants and, upon the discovery of PFAS in Bennington, Vermont, added that class of chemicals to their restrictions as well. Their list of toxic chemicals is internally determined rather than dictated by legislation like the Toxic Substances Control Act (TSCA), so they have instituted stringent restrictions on what they use in their products well beyond the regulations set forth by TSCA. This interview gave great insight into PFAS restrictions at the production level and highlighted the feasibility of PFAS-free alternative packaging options. Martin Wolf did acknowledge, though, that while all of their products are free of PFAS and many are biodegradable, they are still entering the waste stream and, for those products sourced within Vermont, are thus still impacting the Coventry landfill.

To contextualize the internal restrictions at Seventh Generation within existing legislation on chemical use in packaging, we attended the Toxics in Packaging Clearinghouse (TPCH) webinar hosted by Minnesota Pollution Control Agency and Chair of TPCH, John Gilkeson. TPCH has been an influential force in creating the Model Toxic Packaging Law (MTPL) which was implemented to restrict the intentional and incidental use of lead, cadmium, mercury, hexavalent chromium throughout the manufacturing process and in final products of packaging. First introduced in 1990, this law has been continuously amended and, as of 2017, a new list of chemicals of concern, including PFAS, was added to the law. This law, supported by TPCH, has

16 been adopted by states like Maine and Washington which continue to expand upon the law further restricting the use of toxics in packaging. Recently, Maine has banned PFAS on food packaging, effective two years after alternatives were identified, and Washington’s amendment is to presently ban PFAS in all fiber-based food products. The original MTPL utilizes EPR with monetary penalties for noncompliance and some certification for participating consumers. While Vermont is not a member of the TPCH, it did support the original model law and continues to back the updates and amendments made by the organization (See Appendix) (Gilkeson, 2021). Our interview with Martin Wolf and the TPCH webinar has shown that there is existing legislation that has been effective at restricting the use of PFAS and that it is possible to find reasonable alternatives for those still using these chemicals in their products. These results have informed our recommendations to include specific EPR practices for restricting the introduction of PFAS into the Coventry landfill.

After conducting community interviews, we were able to establish a tentative baseline for community understanding of PFAS within the community. While many of the individuals we interviewed had heard of PFAS before, they had little knowledge of PFAS prevalence within household items such as couches and carpets. All participants we interviewed were interested in partaking in the proposed upcycling campaign (see Discussion- Middlebury Upcycling Campaign). We want to acknowledge that the baseline understanding of PFAS from our participants—due to the relatively small sample size—cannot be taken as representative of the Middlebury/ Addison County community.

Discussion Readdressing the initial concerns of Casella, we sought to extrapolate the key figures of each aspect of our research to determine how representative the data provided in the SHA report were of the state of Vermont in addition to the uniqueness of Vermont on a regional and national scale. The data were dually used to identify the limitations of the report and to inform possible solutions and recommendations.

Firstly, we noted the SHA report excluded Residential MSW from their sampling. While it would not change the outflux of PFAS in the landfill, the exclusion of residential MSW in this study would likely affect the mass flux under the assumption that this particular category of waste (residential) would contain significant concentrations of PFAS. The leachate measured as the outflux of PFAS in the landfill would include all the waste content in NEWSVT as it would be impossible to differentiate the components contributing to the leachate once they had entered the landfill. The SHA report would have then included the Residential MSW in their outflux measurement but excluded it from the influx measurement. As carpets, bulky items and textiles have been identified as key contributors of PFAS to the waste stream and together comprise 9.4% of the Residential MSW waste stream, we can assume that they would contribute significantly to the influx of PFAS in the landfill. This also suggests that Casella’s sequestration rate is even higher than originally anticipated given that addition of residential MSW would increase the influx, but not affect the outflux of PFAS.

The 2018 Waste Characterization report from the Vermont ANR provided a view of Vermont over time, within a regional context and, with information from the 2019 Diversion and Disposal report, as an aggregated representation of the current waste stream (DSM

17 Environmental Services, 2018; Waste Management & Prevention Division & Solid Waste Management Program, 2020). The findings derived from this report suggest that significant introductions of recovery and diversion legislation like the Universal Recycling Law have significantly changed the waste stream and thus support the introduction of other similar legislation. The report also supported the SHA report’s representation of the Vermont waste data with significant similarities between high PFAS concentration items and high weight contributors to the landfill. The ongoing PFAS and waste management research in Australia demonstrates that Casella’s findings regarding the most prevalent PFAS found in leachate are consistent and reasonable. In addition, including concentrations by waste stream at such a high spectral resolution (seven waste streams in the SHA report versus three in the Australian case study) indicate that Casella’s waste resource testing goes above and beyond the bare minimum in locations around the world; it is also, importantly, well-guided in that the carpet and bulky items waste streams do appear to be prominent PFAS contributors. Nonetheless, the science of understanding PFAS and PFAS leachate, and knowing how to combat it is constantly evolving; as a result, here we present several proposals to mitigate PFAS in the Coventry waste stream.

Recommendations and Solutions

Waste diversion and recovery have been proven through various state and country-wide studies to be effective in reducing the influx of waste into landfills. Vermont operates two large Material Recovery Facilities (MRF) which process the majority of the state’s diverted materials. These items are separated from the waste stream due to legislation like Vermont’s existing Universal Recycling Law (Act 148), Extended Producer Responsibility (EPR), Bottle Bill, Household Hazardous Waste, and other solid waste programs, then processed and distributed to various markets. These tactics have been successful in targeting specific materials within the waste stream and so a continuation of this recovery legislation with a unique emphasis on products with known inclusion of PFAS is thus essential to the management of PFAS within the waste stream.

Furthermore, EPR specifically has had drastic effects on individual waste streams such as paint and batteries. We believe that an introduction of a PFAS specific EPR would be crucial to tracking and containing highly concentrated PFAS materials that, as shown by the 2019 SHA report, constitute large portions of the overall waste tonnage in Vermont (Sanborn, Head & Associates, Inc., 2019a). This PFAS EPR would require manufacturer source testing to determine which companies are still using these chemicals in production. Additionally, a close partnership with legislators would be necessary to enforce this program; possibly utilizing monetary penalties and certificates of compliance as outlined by John Gilkeson in the TPCH webinar (Gilkeson, 2021).

While many current practices offer options for recommendations and solutions for PFAS management in the Coventry landfill, opening a second landfill in the state has been discussed. As required by Vermont Act 69 passed in 2019, the 2021 Biennial Report on Solid Waste included a study on the opening of a second landfill in the state (Vermont Agency of Natural Resources, 2021b). This study addressed the motivations behind this suggestion, such as reducing the greenhouse gas emissions from transporting waste, as well as the identified issues

18 with siting a new landfill such as limitations surrounding the control of waste flow (Vermont Agency of Natural Resources, 2021a). This plan was further challenged in the Report Responsiveness Summary to Comments on the Biennial Report. We agree with both the commenters, Lamoille Regional Solid Waste Management District and Conservation Law Foundation, and the ANR that this would not be feasible and the attention should be focused on better recovery programs and waste reduction methods (Vermont Agency of Natural Resources, 2020).

Additionally, we are recommending a campaign which is the culmination of our research into diversion and recovery tactics as well as a tool for community engagement and personal relations for Casella. Below is the outline for the Middlebury Upcycling Campaign.

Middlebury Upcycling Campaign

Goals

We understand the importance of community engagement to the success of Casella’s goals. To obtain a baseline understanding of PFAS within the community we conducted a handful of interviews. We connected with these individuals through Front Porch Forum and while the people we interviewed had heard of PFAS to some extent, we recognize this is not representative of the rest of the community. When we told these individuals that PFAS was likely prevalent in their homes, many of these people wanted to throw away these items. This goes directly against our goals and we knew that we had to generate another option to reduce household PFAS exposure, to better protect the community and reduce the amount entering the landfill.

Anticipated Solutions

The Middlebury Upcycling Campaign would generate collaboration between community members and local businesses within Middlebury and Addison County to tackle the PFAS problem. In this campaign we focus on bulky items, which introduce the greatest amount of PFAS into the landfill after carpets and textiles (Sanborn, Head & Associates, 2019). We have created two main ideas for this campaign that could be expanded upon in the future. The first idea is repurposing old couches and carpets into housing insulation. This idea may seem far-fetched however, similar achievements have been made at the University of New South Wales (UNSW) in Australia. In a research lab led by Professor Veena Sahajwalla, Director of UNSW’s Centre for Sustainable Materials Research and Technology, the team was able to successfully turn old textiles and clothing items into building materials. The lab has been able to generate marble-like slates for counter tops and wood-like flooring (Snell 2018). Additionally, an article in Hunker written by Cynthia Myers describes how an individual can turn old pairs of jeans into housing insulation (2021). Due to their flame retardant and water repelling properties (De Silva et al., 2021), textiles treated with PFAS would be an ideal choice for housing insulation.

The second proposed idea is the reupholstering of old PFAS couches with friendlier fibers. These fibers are ones that meet the Global Organic Textile Standard (GOTS). This

19 ensures the fabrics are ethically sourced, organically grown and treated without the use of harsh chemicals (Global Standard, 2020). In their most recent 2020 version, GOTS prohibits all use of per- and polyfluoroalkyl substances (Global Standard 2020). Two Sisters Ecotextiles, Ecological Textiles, and Sustainable Textile Supply Chain are all companies that are GOTS certified and would be a good choice for this project.

Obstacles and Next Steps

In the creation of the Middlebury Upcycling Program our team ran into a few complications. The first issue associated with the campaign is the lack of waste representation data for Addison County. We reached out to Addison County Waste Management District (ACWMD) and while they were able to provide us with other important information, they had no records of waste composition over the years. Because of the lack of data there would be no bulky item/textile baseline from which we could compare. As such, there would be no way to determine whether the upcycling campaign is succeeding and reducing the amount entering the landfill.

While we have waste data from the Department of Conservation 2018 Waste Characterization Report, it is critical for the beginning stages of the Middlebury Upcycling Campaign to have waste composition data for Addison County in particular. Fluctuations in data annually is not uncommon and if we were to see changes in the next Waste Characterization Report for the entire state, it would be unclear whether it was the result of the upcycling campaign or something else. If we were to see changes in percent Furniture/Bulky Items in an Addison County Waste Characterization Report, with the Middlebury Upcycling Campaign having been underway for a number of months paired with a community survey examining participation in the Middlebury Upcycling Campaign, we could better predict the reason for data changes. ACWMD could collect their data following a similar methodology utilized in the SHA report. This includes sample acquisition and collection for materials of interest, in our case bulky items, at Casella transfer stations in Addison County and conduct follow ups annually (Sanborn, Head & Associates, Inc.). The collaboration between Casella and ACWMD as well as the creation of waste composition data for Addison County would be critical to measure the success of the campaign moving forward.

When proposing the idea of the upcycling campaign to the community in our interviews we were met with an overwhelming amount of support. We asked community members if there would be any obstacles that would prevent them from participating in the upcycling campaign. The main concern was the transportation of these bulky items from the individuals’ homes to their anticipated destination. Who would come pick these items up? Who would bring them back if need be? This is an obstacle that we have not been able to address sufficiently and will require more collaboration between our group and Casella and/or transportation companies in town.

We also recognize that the Middlebury Upcycling Campaign would need advertising for people to learn about and participate in. We asked the community members where they got their waste information and most said if they had questions regarding waste disposal they consulted the ACWMD pamphlet released monthly. To ensure a seamless transition, being able to

20 advertise the Middlebury Upcycling Campaign in this document would increase the likelihood that community members would read about it and participate.

Anticipated Partnerships

Table 7. A list of anticipated tasks and partnerships for the Middlebury Upcycling Campaign as well as their primary location in an attempt to keep business partnerships as local as possible with the exception of textile sourcing. Anticipated Tasks Anticipated Partnerships

Textile Sourcing 1. Two Sisters Ecotextiles 2. Ecological Textiles 3. Sustainable Textile Supply Chain

Upholstery 1. Dr. Toms Furniture Refinishing (Middlebury, VT) 2. Mark’s Upholstery (Middlebury, VT)

Insulation 1. Raymond Renovation and New Construction, LLC (Middlebury, VT) 2. Bugbee Insulation (Williston, VT) 3. Vermont Foam Insulation (Chester, VT)

Collection and Transportation 1. Casella Waste Systems

Education, Community Outreach, Data 1. Addison County Waste Management District Collection (ACWMD) (Middlebury, VT)

Further Research We have determined that many of the assumptions in the Sanborn, Head and Associates (SHA) PFAS waste resource testing report are consistent with Vermont waste characterization data, in terms of the effect of waste disposal rates on PFAS mass flux estimates. Future research should consult current Vermont waste characterization data in order to keep an up-to-date proxy for waste disposal rates, used to estimate mass flux. With regard to waste disposal composition, we recommend that future research more aggressively vet those waste streams that, based on prior research and knowledge of PFAS in use, are suspected to contain PFAS by creating subcategories for waste streams. As an example, food packaging in the SHA report was grouped under the waste stream ‘commercial customer waste.’ Because of both the prevalence and complexity of the PFAS food packaging problem, we recommend that future studies focus specifically on food packaging as a waste stream in its own right. Proxies for the mass flux of PFAS from food packaging can be developed based on known quantities of food packaging that are paper or paperboard (the only type of food packaging approved for PFAS application), or the known quantities of food packaging that are above the detection limit for total fluorine testing. A recent study determined that 33% of food packaging from the top U.S. burger chains—McDonald’s, Burger King, and

21 Wendy’s—contained PFAS (Dickman et al., 2020); moreover, nearly half of all food packaging samples tested positive for PFAS. A simple estimate for the mass flux of PFAS from food packing could come from taking the average concentration of PFAS as determined from sampling and multiplying the concentration by half of all food packaging waste. Major companies such as Taco Bell, Panera Bread, Chipotle, Whole Foods, Sweetgreen, Cava, and even Wendy’s have committed to a PFAS phaseout in their products (Toxic-Free Future, 2020). Future sampling for a ‘food packaging’ waste stream could also take the approach determining the proportion of these companies’ products in the sample and extrapolating the proportion of food packaging that is PFAS-free in the landfill; and inversely, the proportion that contains PFAS in the landfill. Lastly, we have determined that any future study in the landfill should conduct testing on MSW from residential sources. As a waste stream, residential MSW has many overlaps with documented waste streams in the SHA study, including C&D and commercial customer waste. Thus, it is likely that residential MSW is a source of PFAS influx for Casella’s landfill that has gone undetected (US EPA, 2018).

Conclusion We believe that the most important way to deal with PFAS in our waste stream is to raise awareness and engagement in the community. While legislation and regulation are really important to phase out PFAS from our waste stream, those sectors move incredibly slowly. Community engagement and education, however, have immediate impacts—from families changing consuming behavior to more people calling their representatives about PFAS to people in the community communicating and informing others about it. Through community education and commitment, the upcycling campaign can work very well keeping PFAS out of our waste stream and in result out of groundwater and communities. The upcycling campaign represents the longevity of these bulky items; and how with the proper care they can be a zero risk for exposure whether in couches, carpets or insulation. If any local grocery store is campaigning for people not to throw out bulky items and to pass them along, for the sole purpose of keeping dangerous chemicals out of their ground, any Vermonter would do that.

Our report stresses the need for further research and specific PFAS testing in our waste management processes. There needs to be layers to waste representation data in all counties in the US. Having specific waste representation data for Addison County will allow programs like the Middlebury Upcycling Campaign to take off and really make a difference. The SHA report urges the expansion of sampling in the municipal solid waste management industry. SHA also emphasizes the need for more manufacturing-specific research on products like food packaging as well as additional Vermont DEC reports. Casella is already laying the groundwork for an industry standard with more specific testing and research on PFAS leachate, PFAS flux, and products containing high amounts of PFAS. In addition, Casella’s waste resource testing goes above and beyond the bare minimum in locations around the world; it is also, importantly, well- guided in that the carpet and bulky items waste streams do appear to be prominent PFAS contributors. Our project and specifically the Middlebury Upcycling Campaign, with more time and outreach to the community, would really help with keeping PFAS out of our landfills and waste management process as much as possible.

22 Acknowledgements

We would like to thank Kim Crosby, Samuel C. Nicolai, and Casella Waste Inc. for their guidance and willingness to engage with us as community partners. We would also like to thank Kate Crawford, Diane Munroe and the rest of the students of ENVS 401 for guidance, advice, and collaboration.

23 Bibliography

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24 "How to Make House Insulation From Blue Jeans." Hunker. Web. 14 May 2021.

Lang, J. R., Allred, B. M., Field, J. A., Levis, J. W., & Barlaz, M. A. (2017). National Estimate of Per- and Polyfluoroalkyl Substance (PFAS) Release to U.S. Municipal Landfill Leachate. Environmental Science & Technology, 51(4), 2197–2205. https://doi.org/10.1021/acs.est.6b05005 Midatlantic Solid Waste Consultants & DSM Environmental Services. (2013). State of Vermont Waste Composition Study [Final Report]. State of Vermont, Department of Environmental Conservation. Per- and Polyfluoroalkyl Substances (PFAS). (2020). In Technical/Regulatory Guidance. Interstate Technology Regulatory Council. PFAS Technical and Regulatory Guidance Document and Fact Sheets. (2020). Interstate Technology and Regulatory Council. PFAS Contamination in the U.S. (January 6, 2021). (n.d.). EWG. https://www.ewg.org/interactive-maps/pfas_contamination/ PFAS in the U.S. Population. (2020). Agency for Toxic Substances and Disease Registry. https://www.atsdr.cdc.gov/pfas/health-effects/us-population.html Robey, N. M., da Silva, B. F., Annable, M. D., Townsend, T. G., & Bowden, J. A. (n.d.). Concentrating Per- and Polyfluoroalkyl Substances (PFAS) in Municipal Solid Waste Landfill Leachate Using Foam Separation. Environmental Science and Technology, 54(16), 12550-12559. Romano, M. (2021). Influence of PFAS on adiposity & physical growth across the lifecourse. Sanborn, Head & Associates, Inc. “PFAS Waste Source Testing Report: New England Waste Services of Vermont, Inc.” Coventry, Vermont Solid Waste ID No. OL510. Prepared for New England Waste Services of Vermont, Inc. File No. 4536.00. October 2019. Silva, A. O., Armitage, J. M., Bruton, T. A., & Dassuncao, C. (2021, November). PFAS Exposure Pathways for Humans and Wildlife: A Synthesis of Current Knowledge and Key Gaps in Understanding. Environmental Toxicology and Chemistry, 40(3), 631-657. Snell, Stuart. "Turning Old Clothes into High-end Building Materials." Phys.org. Phys.org, 19 Dec. 2018. Web. 14 May 2021. Staley, B., & Barlaz, M. (2009). Composition of Municipal Solid Waste in the United States and Implications for Carbon Sequestration and Methane Yield. Journal of Environmental Engineering-Asce - J ENVIRON ENG-ASCE, 135. https://doi.org/10.1061/(ASCE)EE.1943-7870.0000032 Sunderland, E. M., Hu, X. C., Dassuncao, C., Tokranov, A. K., Wagner, C. C., & Allen, J. G. (2019). A review of the pathways of human exposure to poly- and perfluoroalkyl substances (PFASs) and present understanding of health effects. Journal of Exposure Science & Environmental Epidemiology, 29(2), 131–147. https://doi.org/10.1038/s41370- 018-0094-1

25 Toxic-Free Future. “PFAS-Free Paper Food Packaging Alternatives: A Resource for Restaurants and Retailers.” Toxic-Free Future, 7 Dec. 2020, https://toxicfreefuture.org/pfas-free- paper-food-packaging-alternatives-a-resource-for-restaurants-and-retailers/. Treating PFAS in Drinking Water. (n.d.). EPA: United States Environmental Protection Agency. https://www.epa.gov/pfas/treating-pfas-drinking-water US EPA, ORD. “Practical Methods to Analyze and Treat Emerging Contaminants (PFAS) in Solid Waste, Landfills, Wastewater/Leachates, Soils, and Groundwater to Protect Human Health and the Environment.” US EPA, 17 Aug. 2018, https://www.epa.gov/research- grants/practical-methods-analyze-and-treat-emerging-contaminants-pfas-solid-waste- landfills. Vermont Agency of Natural Resources, D. (n.d.). Universal Recycling Summary Sheet. https://dec.vermont.gov/sites/dec/files/wmp/SolidWaste/Documents/Universal- Recycling/UR_SummarySheet_CURRENT.pdf Vermont Agency of Natural Resources, D. (2019). 2019 Vermont Materials Management Plan: Reducing Solid Waste & Increasing Recycling and Composting. https://dec.vermont.gov/sites/dec/files/wmp/SolidWaste/Documents/2019%20Final%20V T%20MMP.pdf Vermont Agency of Natural Resources, D. (2020, November 6). 2021 Biennial Report Responsiveness Summary. https://dec.vermont.gov/sites/dec/files/wmp/SolidWaste/Documents/2021-Biennial- Report-Responsiveness-Summary%20.pdf Vermont Agency of Natural Resources, D. (2021). 2021 Biennial Report on Solid Waste. Vermont House & Senate Committees on Natural Resources. Vermont Agency of Natural Resources, DEC. (2021). EPR Program Table 2019 Data (2021 Biennial Report on Solid Waste,). https://dec.vermont.gov/sites/dec/files/wmp/SolidWaste/Documents/Universal- Recycling/EPR-program-table-2019-data.pdf VPIRG. (2021, March 19). Vermont Senate Advances Bill to Ban Toxic PFAS Chemicals. Vermont Public Interest Research Group. https://www.vpirg.org/issues/toxics-and- environment/vermont-senate-advances-bill-to-ban-toxic-pfas-chemicals/ Waste Management & Prevention Division & Solid Waste Management Program. (2020). 2019 Diversion and Disposal Report. Vermont Agency of Natural Resources, DEC. https://dec.vermont.gov/sites/dec/files/wmp/SolidWaste/Documents/2019-Diversion-and- Disposal-Report.pdf

26 Appendix Below is a list of terms/reports/organization addressed in this report. We have included links for for additional information.

Term Link

Waste Management and Prevention | Solid Publications and Reports | Department of Waste: Publications and Reports Environmental Conservation (vermont.gov)

Extended Producer Responsibility EPR-program-table-2019-data.pdf (vermont.gov)

Universal Recycling Law 2019.Universal.Recycling.Status.Report.pdf (vermont.gov)

Single Use Product Law Single-Use Products Law | Department of Environmental Conservation (vermont.gov)

Bottle Bill Vermont's "Bottle Bill" | Department of Environmental Conservation

Toxics in Packaging Clearinghouse Webinar https://drive.google.com/file/d/18NzSozNiW1 vyyxC70Mmw- O5T8OuuzC0A/view?usp=sharing

Lamoille Regional Solid Waste Management Lamoille Regional Solid Waste Management District District – Serving the Member Towns of: Belvidere, Cambridge, Craftsbury, Eden, Elmore, Hyde Park, Johnson, Morrisville, Stowe, Waterville, Wolcott, & Worcester (lrswmd.org)

Conservation Law Foundation Conservation Law Foundation | For New England (clf.org)

Addison County Waste Management District https://drive.google.com/file/d/1cPxWsIPg1n DUPJme4i4EbP9D8Kem3Y0a/view?usp=sha ring