DoD’s Interim Guidance

On July 11, 2023, the Department of Defense (DoD) issued a memorandum, Interim Guidance on Destruction or Disposal of Materials Containing Per- and Polyfluoroalkyl Substances in the United States. The memo flew under the radar for many stakeholders involved in the PFAS debate, with few publications reporting on the environmental developments. However, the memo provides excellent insight into how the DoD would like to handle the PFAS contamination found on its installations.

The Memo, In Summary

The memo identified four commercially available options to destroy or dispose of DoD PFAS-containing materials:

Carbon reactivation units with environmental permits (for used granular activated carbon only).
Hazardous waste landfills with environmental permits.
Solid waste landfills that have composite liners and gas and leachate collection and treatment systems, with environmental permits.
Hazardous waste incinerators with environmental permits.

In addition to these four DoD-wide options, the DoD Components are directed to consider other options, based on the specific site, for storage of over ninety days. These options could include onsite hazardous waste storage, underground injection, and other existing and developing technologies, such as thermal desorption, permitted at the State or Federal level.

The memo was followed by a second memorandum, published on July 14, 2023, which clarified that although incineration is included as an option within the original guidance, additional time is needed before any incineration operations resume. Thus, DoD Components are prohibited from incinerating PFAS-containing materials until authorized by another memo.

Next Steps: What to Expect from the DoD

The DoD intends to update this memo at least annually. As stated in the original memo, the updates will reflect changes as technologies develop, as the Environmental Protection Agency (EPA) updates its guidance, and when additional data becomes available.

In the meantime, the DoD has halted its use of incineration and needs to complete a National Environmental Policy Act(NEPA) Review. The Defense Logistics Agency (DLA) is conducting this review in which we can expect a public comment period.

The ReSolve Difference

Enviri Corporation’s Government Relations Team regularly contacts the DoD on behalf of Clean Earth, providing comments and feedback as experts in the disposal and destruction market. Clean Earth’s ReSolve program plans to publish the Company’s stance on facilitating more robust guidance on PFAS in the coming weeks. Additionally, ReSolve will provide updates on the EPA’s pending guidance. Check back for our updates on these topics here.

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