Comment submitted by PacTec, Inc.

Introduction PacTec, Inc. appreciates the opportunity to comment on the U.S. Environmental Protection Agency’s (EPA’s) April 2026 Interim Guidance on the Destruction and Disposal of Per and Polyfluoroalkyl Substances (PFAS) and PFAS Containing Materials. PacTec is a manufacturer of engineered flexible packaging systems used globally for the containment, transportation, and storage of contaminated materials, soils, sludges, industrial byproducts (hazardous and nonhazardous), and environmental remediation wastes including low level radioactive wastes. EPA Recognition of Interim Storage (1.c.) EPA’s guidance acknowledges: “Interim storage with controls” as a viable short term management option in certain circumstances, primarily for containerized or high concentration PFAS materials, situations where PFAS waste is awaiting treatment or disposal, and transportation of PFAS waste to treatment or disposal sites and should be considered a temporary solution. Identified Gap in the Guidance While EPA recognizes interim storage as an important tool, the 2026 Interim Guidance does not provide specific recommendations regarding container systems, performance criteria, or technologies suitable for interim storage of PFAS containing materials. Given EPA’s overarching objective to minimize PFAS release, the absence of guidance on storage system performance characteristics represents an important gap for industry and regulators. Engineered Flexible Packaging as an Interim Storage Solution PacTec recommends that EPA consider engineered flexible bulk containment systems in a range of sizes (e.g., high performance bulk bags with compatible liners) as a viable technology for interim storage of PFAS contaminated materials when used with appropriate controls. Engineered flexible containment systems support EPA’s objectives by 1) minimizing release potential through multi layer construction and liner systems designed to reduce leakage and migration pathways, 2) reducing handling and transfer of waste which reduces re handling compared to smaller containers, lowering potential exposure, 3) supporting site specific flexibility suitable for a range of PFAS waste streams, including soils, sediments, dewatered sludges etc. and, 4) addressing infrastructure and capacity constraints allowing scalability for large remediation projects where rigid container logistics may be limiting. Appropriate Use Cases for Engineered Flexible Packaging PacTec encourages EPA to consider the success of engineered, soft-sided packages in adjacent hazardous waste use cases. Specifically, we would like to draw EPA’s attention to soft-sided packaging safely containing Class 7 low level nuclear waste at DOE remediation sites, and point to the economic, logistical, and operational benefits when compared to metal containment structures. Beyond Class 7 wastes, soft-sided packages have successfully contained, for transport and disposal, hundreds of hazardous waste stream types from industrial hazardous waste generators. Recommended Additions to the 2027 Guidance (1.c.i) PacTec respectfully recommends that EPA include the following in future updates. Language such as: “Engineered flexible bulk containment systems, including high strength bags with compatible liners, may be appropriate for interim storage of PFAS contaminated materials when designed and managed to prevent releases.” EPA could also improve clarity by identifying general performance criteria, including resistance to PFAS leakage and material migration, chemical compatibility with PFAS containing media, mechanical durability (handling, stacking, transport), resistance to environmental conditions (UV, precipitation), and compatibility with secondary containment systems. Commitment to Support EPA PacTec is committed to supporting EPA’s efforts to improve PFAS waste management and would welcome the opportunity to provide technical data and case studies, participate in pilot programs or demonstrations, and collaborate on best practices for interim storage systems. Conclusion PacTec supports EPA’s recognition of interim storage as a necessary component of PFAS waste management. Expanding the guidance to include engineered flexible containment systems will provide regulators and site managers with practical, scalable tools that align with EPA’s central objective of minimizing environmental releases. We appreciate EPA’s consideration of these comments.