Interim PFAS Destruction and Disposal Guidance; Notice of Availability for Public Comment

The National Association of Clean Water Agencies (NACWA) supports the EPA's 2026 Interim PFAS Destruction and Disposal Guidance but requests additional context regarding the operational and financial burdens of incineration and landfilling. They specifically advocate for the inclusion of information regarding industrial pretreatment programs and the recognition of land application as a regulated, beneficial use of biosolids.

StreamGo Water Solutions Inc. supports the EPA's interim guidance but argues that it is outdated regarding recent advancements in PFAS separation and destruction technologies. The company advocates for the inclusion of more cost-effective and less energy-intensive technologies, such as advanced reduction processes (ARP), in the final guidance document.

The Chemours Company submitted comments regarding the EPA's Interim Guidance on PFAS Destruction and Disposal. They express support for the updated guidance while providing specific technical recommendations to improve clarity on PFAS terminology, differentiate fluoropolymers from non-polymers, and refine the data regarding thermal destruction methods and municipal waste combustor operations.

Onvector LLC, an emerging technology company, supports the EPA's updated Technology Evaluation Framework and requests that plasma-based destruction be included as a highlighted emerging technology in the Guidance. They argue that their proprietary Plasma Vortex technology has demonstrated high destruction efficiency and safety in various federally funded and private-sector programs.

The California Association of Sanitation Agencies (CASA), representing over 150 public agencies and municipalities, supports the EPA's Interim PFAS Destruction and Disposal Guidance. They advocate for evidence-based, cost-effective, and scalable destruction technologies while emphasizing the importance of continued research and real-world testing to protect public health and resource recovery programs.

WM, a leading environmental services provider, supports the EPA's interim guidance on PFAS destruction and disposal, specifically noting the importance of modern landfills as a disposal option. The company offers to collaborate on research regarding fate and transport, emissions testing, solidification and stabilization, and the development of a practical decision framework for landfill disposal.

Environmental Clean Technologies Limited supports the EPA's new technology evaluation framework and recommends making a closed fluorine mass balance an explicit first-order evaluation criterion. They argue that measuring the fate of fluorine is essential to ensure that PFAS destruction doesn't simply result in the migration of fluorine into unmeasured short-chain products or volatile gases.

A coalition of environmental and community organizations opposes the 2026 Interim Guidance because it eliminates protections for vulnerable populations, fails to prioritize the most protective disposal methods over cost, and removes references to relevant Clean Water Act permitting. They argue that the guidance is insufficient to prevent the spread of PFAS pollution and urge the EPA to establish formal health-protective regulations.

Revive Environmental Technology, LLC, a commercial PFAS destruction company, supports the EPA's science-based approach but argues that the 2026 Guidance is outdated regarding supercritical water oxidation (SCWO) technology. They request that the EPA update its records to recognize SCWO as a commercially available, regulator-permitted destruction option supported by recent peer-reviewed data and commercial-scale performance.

The New Mexico Environment Department (NMED) supports the EPA's efforts to address PFAS destruction but urges the agency to transition from non-binding guidance to a federally enforceable regulatory framework. They advocate for stricter standards, including mandatory mineralization, specific operating parameters for incinerators, and the formal listing of PFAS as hazardous waste under RCRA.