DOD Releases Report to Congress Declining Need for Formal Program for Non-Incineration Destruction of PFAS
The Department of Defense (DOD) Office of the Assistance Secretary for Energy, Installations, and Environment released a report this month titled “Per- and Polyfluoroalkyl Substances Non-Incineration Destruction Technologies Report to Congress.” The Report was released in response to a House Report accompanying the Fiscal Year 2024 National Defense Authorization Act in which the House Armed Services Committee asked DOD to submit a report to the Committee on whether DOD could incorporate non-incineration technologies into DOD’s strategy for disposing of PFAS and PFAS-containing wastes. In the Report, DOD states that a formal program to pilot-test non-incineration technologies to destroy PFAS is not needed because DOD is already demonstrating non-incineration technologies under existing research programs. The Report indicates that DOD plans to update its own interim PFAS destruction and disposal guidance, which was originally issued in July 2023, by the end of 2024.
This Report comes in the wake of the Environmental Protection Agency’s (“EPA”) Interim Guidance on the Destruction and Disposal of PFAS, released in April 2024, in which incineration is listed as an option for PFAS destruction, but prioritizing non-incineration-based destruction and disposal methods, such as underground injection and permitted hazardous waste landfills. In its Interim Guidance, EPA encourages decision-makers to prioritize the use of technologies with lower potential for PFAS release to the environment. Incineration requires extremely high temperatures and specific conditions to effectively destroy PFAS and there is currently not enough research to determine whether PFAS are completely broken down from incineration technologies or if there is potential for releases to the environment.
Effective and efficient treatment, disposal, and destruction of PFAS waste will continue to be the subject of research and regulation as more and more standards and restrictions for PFAS compounds are developed.