(January 7, 2021) – Just before the holidays, EPA published an interim guidance document on PFAS destruction and disposal and is seeking public comment by February 22, 2021. NACWA is closely reviewing the document but is also interested in any member feedback.  

NACWA was anticipating this interim guidance because, pursuant to the Fiscal Year 2020 National Defense Authorization Act (NDAA), the agency was required to publish guidance on the possibility of destruction and disposal options for six specific types of materials that contain PFAS, including soils and biosolids. EPA’s interim guidance is looking at thermal treatment, landfilling, and underground injection as three mechanisms to destroy or dispose of PFAS or PFAS- containing materials.

EPA made clear in the interim guidance that biosolids land application is outside the scope of this document because land application is neither a destruction or disposal method. However, the language EPA used to carve out land application and subsequent discussion in the guidance identify land application as potentially causing or contributing to PFAS migration.  

EPA’s interim guidance also mentions sewage sludge incineration as a possible thermal treatment technique, although hazardous waste combustion is identified as having the “greatest potential” among the thermal treatment options.  

NACWA is reviewing the document closely and would appreciate members taking a close look at EPA’s assumptions and language provided in the interim guidance. There is a tremendous amount of detail to unpack and the Association appreciates any member feedback or input as we prepare comments. 

Please contact Emily Remmel if you have thoughts on the interim guidance or would like more information.