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

StreamGo Water Solutions Inc. supports the EPA's interim guidance but argues that it is outdated regarding recent advancements in PFAS separation and destruction technologies.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.

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.

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.

The Association of Metropolitan Water Agencies (AMWA) supports the EPA's efforts to provide PFAS destruction and disposal guidance but argues that the current interim version lacks sufficient clarity regarding liability, specific waste stream diversity, and quantitative concentration thresholds. They request more user-oriented resources, clearer decision criteria for landfill disposal, and a realistic assessment of existing infrastructure capacities.

A coalition of industrial and trade associations supports the EPA's updated Interim PFAS Destruction and Disposal Guidance, provided it remains flexible, science-based, and avoids a rigid technology hierarchy. They argue for the continued use of established disposal methods like landfilling and incineration while calling for a transparent, predictable pathway for emerging technologies and alignment with Department of Defense guidance.

HRP Associates, Inc. supports the EPA's commitment to iterative updates but argues that the current guidance is too narrow in its focus on thermal treatment and containment. The company recommends that the EPA explicitly include and evaluate non-thermal waste minimization technologies, specifically Rapid Leaching Technology (RLT), in the next version of the guidance.

The Environmental Technology Council (ETC), a national trade association representing commercial firms in waste disposal and recycling, supports the EPA's interim guidance on PFAS destruction and disposal. They advocate for the inclusion of various technologies—specifically RCRA-regulated incineration, deep well injection, and thermal desorption—while urging the EPA to avoid setting specific operational parameters (like temperature) that might unfairly disadvantage certain technologies.

The National Waste & Recycling Association (NWRA) supports the EPA's efforts to update the PFAS destruction and disposal guidance but requests more clarity and balance in the document. They argue that the guidance should explicitly recognize modern Subtitle D landfills as a necessary and effective management pathway for large volumes of non-hazardous PFAS-containing materials, while also incorporating more science-based evidence regarding PFAS sequestration in solid phases.

The Massachusetts Water Resources Authority (MWRA), a public utility, supports the EPA's efforts to update the PFAS destruction and disposal guidance while emphasizing the need for more recognition of municipal utilities as passive receivers of PFAS. They argue that source reduction is the most effective long-term strategy and call for greater acknowledgement of the financial, capacity, and liability constraints facing biosolids management.

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.