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

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.

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.

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.

Public Employees for Environmental Responsibility (PEER) opposes the interim guidance, arguing that the proposed disposal methods (landfilling, incineration, and injection) are unreliable and potentially harmful to human health and the environment. They urge the EPA to adopt a broader definition of PFAS, regulate them as a class, and ban all non-essential uses rather than focusing on destruction methods for chemicals that are still being manufactured and used.

Waterkeeper Alliance opposes the proposed Interim PFAS Destruction and Disposal Guidance, arguing that the methods discussed—specifically thermal treatment, landfilling, and Class I well injection—pose significant risks to human health and the environment. They urge the EPA to continue researching safer disposal methods and to focus on reducing PFAS production rather than endorsing what they characterize as "half measures."

Three Rivers Waterkeeper, an environmental advocacy organization, supports the EPA's interim guidance but urges the agency to strengthen future updates. They argue for more explicit discussion on the long-term risks of landfilling and underground injection, the potential for PFAS transfer in wastewater systems, and the need for better monitoring of thermal treatment residuals.

The Water Quality Association (WQA), a non-profit representing the water treatment industry, supports the EPA's efforts to provide PFAS destruction and disposal guidance but urges the agency to distinguish between industrial waste and small-scale drinking water treatment residuals. They argue that the guidance should use a risk-based framework to ensure that technologies used by consumers to protect public health are not unfairly burdened by regulations intended for primary PFAS source materials.

The New Jersey Department of Environmental Protection (NJDEP) supports the EPA's efforts to update the interim guidance on PFAS destruction and disposal, commending the inclusion of new science and analytical methods. However, the NJDEP urges the EPA to address specific data gaps, such as the need for a formal waste classification system, clearer performance criteria for destruction technologies, and more robust protections for vulnerable communities.

The Wyoming Department of Environmental Quality (WDEQ) supports the EPA's 2026 Interim Guidance on PFAS destruction and disposal but requests more specific, plain-language recommendations for various waste streams. They also advocate for more frequent updates, the inclusion of recent regulatory changes (like CERCLA hazardous substance designations), and the creation of additional online resources to assist decision-makers.

The commenter urges the EPA to revise the Interim Guidance to include mandatory human health and ecological risk assessments for PFAS destruction and disposal methods. They argue that certain methods, like thermal treatment, could create new exposure pathways and that the current guidance fails to adequately address the risks posed by known carcinogens like PFOA and PFOS.