June 17, 2024

Interim Guidance on Destruction and Disposal of PFAS and PFAS-Containing Materials

In December 2020, EPA published the first edition of its interim guidance on destruction and disposal (D&D) technologies for per- and polyfluoroalkyl substances (PFAS) and PFAS-containing materials. On April 16, 2024, the agency published an update to this interim guidance for managing these forever chemicals. [89 FR 26879] In the updated guidance, EPA emphasizes the importance of D&D technologies that minimize PFAS releases into the environment. Underground injection, landfills, and thermal treatment were highlighted as the best D&D methods to meet this release minimization goal.

SDWA-permitted Class I nonhazardous industrial or hazardous waste injection wells have a lower potential for release into the environment. The construction, operation, and monitoring standards for Class I injection wells are designed to contain liquid wastes and prevent groundwater contamination, making them an effective method for PFAS D&D. However, not many injection wells are actively receiving PFAS, significantly limiting this D&D method.

Hazardous waste landfills have substantial engineering controls and practices, making them suitable for PFAS D&D. EPA highlighted how the low leachate volumes from RCRA-permitted hazardous waste landfills further decrease the chances of PFAS being released into the environment. However, new information shows landfills could produce higher than anticipated PFAS releases than previously thought in 2020, casting some doubt on this method of PFAS D&D.

Thermal treatment in RCRA-permitted hazardous waste combustors such as commercial incinerators, cement kilns, lightweight aggregate kilns, and granular activated carbon reactivation units are recommended for PFAS D&D. Despite this recommendation, EPA acknowledges that little information has been found since 2020 on the actual effectiveness of thermal treatment on PFAS and encourages such facilities to conduct additional testing to ensure the effectiveness of thermal treatment on PFAS-containing waste streams. The agency continues to seek collaboration with thermal treatment facilities to monitor air emissions during the thermal treatment of PFAS-containing waste streams. Additional guidance on air emissions is provided in Appendix A of the interim guidance document.

EPA has partnered with industry and academia to collect data on four emerging technologies for PFAS destruction: mechanochemical degradation, electrochemical oxidation, gasification and pyrolysis, and supercritical water oxidation. Additional research on these technologies is needed to further evaluate their effectiveness. Comments on the updated interim guidance may be submitted until October 15, 2024 via Docket ID No. EPA-HQ-OLEM-2020-0527.

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