The EPA recently released “Interim Guidance on Destroying and Disposing of Certain PFAS and PFAS-Containing Materials That Are Not Consumer Products,” which identifies available, effective methods to remediate, dispose of, and destroy per- and polyfluoroalkyl substances (PFAS) contamination.

 

The intended audience for the guidance is decision-makers who need to determine the most effective means for destroying or disposing of PFAS-containing materials and wastes, according to the EPA.

The guidance provides information on the current state of science and associated uncertainties for three large-scale-capacity technologies that can destroy PFAS or control PFAS release into the environment:

• Thermal destruction
• Landfills
• Underground injection

“This guidance will help decision-makers select technologies based on characteristics of the waste and options available to prevent releases and keep PFAS out of the environment,” according to an EPA website about the PFAS guidance.

The first edition of this guidance was released by the Agency in 2020, as required by the National Defense Authorization Act for Fiscal Year 2020 (FY20 NDAA). The original guidance addressed the destruction and disposal of PFAS and specific PFAS-containing materials, including aqueous film-forming foam, contaminated media, textiles (other than consumer goods), and various wastes from water treatment. Under the NDAA, the EPA is required to review and update the guidance as appropriate but no less frequently than every 3 years.

The recent update to the guidance includes incorporating information distilled from new EPA test methods, as well as recent findings pertaining to destruction and disposal of PFAS-containing materials in non-consumer settings. It also includes updated screening methods to assess vulnerable populations near PFAS destruction and disposal sites and incorporates comments the EPA received on the original guidance.?

Key findings

In general, the EPA encourages managers of PFAS and PFAS-containing materials to use destruction and disposal (D&D) options that have a lower potential for releasing PFAS to the environment.

The following technologies, according to the EPA, have a lower potential for environmental release of PFAS compared with other technologies within the categories of storage, underground injection, landfilling, and thermal treatment:

• Interim storage with controls: Storage isn’t a D&D technology but may be a short-term option. Storage may be more fitting for some PFAS materials than others. For example, the EPA recommends interim storage of containerized or high PFAS-content materials. In contrast, some materials may be less fit for storage because they’re continuously generated or have high-volume and low-PFAS content. With proper controls in place, interim storage can control PFAS migration.
• UIC–Permitted Class I non-hazardous industrial or hazardous waste injection wells: The standards associated with the construction, operation, and monitoring of these Class I wells are designed to isolate liquid wastes deep below the land surface and ensure protection of underground sources of drinking water. While Class I wells are an option for managing PFAS-containing fluids, this technology may not be appropriate or available everywhere.
• Landfills–Permitted hazardous waste landfills: When landfill disposal is selected and PFAS concentration of the waste is relatively high, the EPA recommends using a hazardous waste landfill. However, for all landfill types, new information shows landfills release more PFAS to the environment than previously thought in 2020. Hazardous waste landfills have leachate emissions protections that help control environmental releases of PFAS. These controls are especially important for certain types of PFAS-containing materials that break down more easily in landfill conditions.
• Thermal treatment–Permitted hazardous waste combustors that operate under certain conditions: New research since 2020 indicates that thermal treatment units operating under certain conditions are more effective at destroying PFAS and minimizing releases or exposures. Certain hazardous waste combustors and certain granular activated carbon (GAC) reactivation units may operate under these conditions, but uncertainties remain. For example, more information is needed to determine whether harmful products of incomplete combustion or PFAS air emissions are formed by units operating at lower temperatures (e.g., municipal waste combustors).

The EPA has also released a new analytical test method, OTM-50, that will help collect more data and answer some of these questions, such as those concerning products of incomplete combustion. The updated interim guidance encourages testing with a range of methods at thermal treatment facilities before accepting large quantities of PFAS-containing materials.

Comments on the updated guidance will be accepted on the federal e-Rulemaking platform under Docket#: EPA-HQ-OLEM-2020-0527-0132 until October 15, 2024.