2d. Day 2_6_ PFAS Construction and Best Management Practices.pdf

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Air Force Installation & Mission Support Center

Best Management Practices for

Addressing PFAS at Construction Sites

Mahalingam Ravichandran, PhD AFCEC PFAS Integrator

Overview Topics

Background Regulatory Framework Dept of War Guidance and Policies Dept of Air Force Best Management Practices

Planning and Programming Phase Design and Construction Phase

Background

Widespread occurrence of PFAS at many construction sites from historical AFFF releases, high GW mobility, low screening levels

Major impacts on cost/schedule of Military Construction (MILCON) and Facilities Sustainment, Restoration, and Modernization (FSRM) projects, affecting mission readiness MILCON Projects programmed years back when PFAS was not an issue No clear disposal standards or cost-effective disposal options MILCON/FSRM use different funding and timelines than DERP cleanup

March 2025 SAF/IEE issued BMPs to avoid, minimize, or manage excavated soil/groundwater impacted with PFAS and other contaminants at MILCON/FSRM sites

Regulatory Framework

DoW conducts environmental cleanup of PFAS under CERCLA Use of Regional Screening Levels for soil/groundwater to determine whether further investigation is needed – RSLs are NOT disposal standards PFOA and PFOS are listed as CERCLA hazardous substances

SDWA (MCLs) – applicable to Public Water Systems, not construction sites

RCRA – not a regulated waste (listed or characteristic) 9 PFAS chemicals were proposed as hazardous constituents under RCRA; it’s unknown if

EPA intends to finalize those rules

State Standards Some states have promulgated PFAS standards for groundwater, surface water, soil etc.

States may have screening levels for soil management, waste disposal

DoW Guidance / Policies

Jan 2026 Guidance for MILCON projects w/ Historical Contamination Planning Phase

Collaboration between planning & env. staff (e.g., use PFAS scoping checklist) Baseline sampling prior to site selection, cost for treatment/disposal in DD 1391 Use Geospatial data to identify contaminated area, LUCs, and in Master Planning

Construction Phase – Management of Impacted Media Dewatering – meet CWA standards, discharge permits Soil – temporary stockpile need engineering and erosion controls

Feb 2026 Updated Interim Guidance on Destruction or Disposal Carbon reactivation units (for used GAC), Haz waste Landfills, Solid waste landfill with liners + gas/leachate collection/treatment systems, Haz waste incinerators, underground injection control wells, thermal desorption, others

SAF/IEE BMPs

March 2025 BMP guidance from SAF/IEE: “Best Management Practices for Addressing Contaminated Soils on Military Construction and Facilities Sustainment, Restoration, and Modernization Projects”

Addresses handling of contaminated soil with all types of contaminants, but emphasis on PFAS, from planning to execution phase

BMPs to avoid, minimize, or manage excavated soil & dewatered fluid in MILCON & FSRM projects

Other BMPs forthcoming - for contaminated construction and demolition debris (e.g., asphalt, concrete, piping, carpet padding, drywall, etc), large dewatering operations

Summary of Soil BMPs

BMPs - Project Planning Phase

Early communication with environmental professionals (e.g., RPMs) regarding potential for contaminants in project footprint, land use controls

Conduct desktop due diligence using GEOMAP and available environmental databases to identify restoration sites, evaluate project area for contaminants in soil, groundwater

Address implication of environmental regulations and funding considerations on project schedule, execution and cost

Efforts underway to include checklists during the planning process

BMPs - Project Design Phase

Project relocation to avoid impacted soil / groundwater

Design alteration or innovative methods to avoid or reduce earthworks and dewatering (e.g., deep foundations, build up, direct push casing instead of trenching)

Minimize excavation and segregate soils to limit generation and stockpiling of impacted soils

Mitigate exposure risks to onsite workers and on-base personnel during project execution

BMPs - Project Execution

Coordinate with RPMs for compliance with applicable regulations, and coordination with regulatory agencies

Soil Management Plan (SMP) for storage, handling and management of soils

Focused investigation and characterization of soil and groundwater in project area where no prior data or limited data Sampling not required unless the area is a known restoration site or there is suspected release Recommend developing a sampling and analysis plan, including a decision matrix, and coordinated with RPMs and regulatory agencies (as required) Compare to applicable standards or screening levels

Contaminated soil will require sampling based on stockpile size

Soil Management If levels are below lab detection levels or screening levels, soils can be reused on-site or disposed without restrictions Soil that contains RCRA hazardous waste have storage limitations (Note: PFAS is currently not regulated as RCRA waste) While not preferred, PFAS-containing soil may be placed back in the same area of excavation, with appropriate documentation for future investigations and ensuring contamination is not spread

Per DoD Interim Guidance, soils impacted with PFAS may be disposed of at RCRA Subtitle C or D landfills (with appropriate permits, liners, and leachate collection systems)

In some cases, in-situ chemical stabilization of soil or modeling of leaching potential to groundwater may allow storage of soil and reduce disposal cost

Contaminated soil stockpile should be protected with impermeable liners to prevent runoff, wind erosion, and leaching to groundwater

Dewatering and Water Treatment Water removed during construction activities must comply with Clean Water Act regulations prior to discharge to surface water or injected to groundwater, including dewatering permits and construction stormwater permits

DAFMAN 32-1067: “Industrial wastewater treated for PFAS or with residual PFAS contamination from known releases will only be discharged in accordance with applicable regulations, permit conditions and AF guidance and policy, and with authorization from receiving treatment works”

For discharge to the sanitary sewer, coordinate and get written permission from the receiving POTW, which may have its own PFAS requirements

Extracted groundwater may be transferred to a centralized water treatment plant ONLY if it is capable of treating for PFAS (most WWTP are not designed to treat for PFAS)

Depending on the concentration, volume and water quality, on-site treatment of water using GAC or Ion-Exchange may be more cost effective

Questions