Attachment 13a 2026 DOD Memo Guidance on Destruction or Disposal of Materials Containing PFAS.pdf

THE ASSISTANT SECRETARY OF WAR

3400 DEFENSE PENTAGON

WASHINGTON, DC 20301-3400

February 20, 2026

ENERGY, INSTALLATIONS,

AND ENVIRONMENT

MEMORANDUM FOR ASSISTANT SECRETARY OF THE ARMY (INSTALLATIONS,

ENERGY AND ENVIRONMENT)

ASSIST ANT SECRETARY OF THE NAVY (ENERGY,

INSTALLATIONS AND ENVIRONMENT)

ASSISTANT SECRETARY OF THE AIR FORCE

(INSTALLATIONS, ENVIRONMENT AND ENERGY)

DIRECTOR, DEFENSE LOGISTICS AGENCY (LOGISTICS

OPERATIONS)

SUBJECT: Updated Interim Guidance on Destruction or Disposal of Materials Containing Per and Polyfluoroalkyl Substances in the United States

The Department of War (DoW) Per- and Polyfluoroalkyl Substances (PFAS) Task Force issues updated interim guidance to help Do W make informed decisions in the evaluation of existing destruction and disposal options for covered Do W PF AS-containing materials. 1 This update takes into account new PF AS disposal and destruction information, including the U.S.

Environmental Protection Agency (EPA) Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl Substances and Materials Containing Perfluoroalkyl and Polyfluoroalkyl Substances, April 8, 2024 (hereinafter referred to as the EPA 2024 guidance), section 330 of the FY 2020 National Defense Authorization Act ("NDAA") (Public Law 116- 92), and section 324 of the FY 2026 NDAA (Public Law 119-60).

Concurrent with this updated Do W guidance on PF AS destruction and disposal, Do W continues to transition to PF AS-free firefighting agents for land-based applications in accordance with section 322 of the FY 2020 NDAA. DoW has determined that this transition, which requires the removal of PF AS-containing firefighting foam (i.e., Aqueous Film Forming Foam (AFFF)) from installation fire protection inventories, generates large quantities ofPF AS containing concentrate and rinsate for which Do W must find safe destruction and disposal solutions.2 In addition, quantities ofPF AS-containing material are generated from Do W's nationwide cleanup program, and recovery of emergency use discharges or spills of AFFF.

These combined quantities exceed Do W's long-term storage capabilities, necessitating Do W to

1Tois guidance applies to Do W's PF AS-containing materials being sent to an offsite commercial facility for disposal or destruction unless the materials are from household or consumer products, or the material qualifies as a hazardous waste under the Resource Conservation and Recovery Act (RCRA). For materials that qualify as RCRA hazardous waste and are mixed with PF AS-containing materials, DoW Components shall follow RCRA regulations and also apply the criteria in this guidance (e.g. temperature requirements for hazardous waste incinerators) for the disposal or destruction option required by RCRA regulations (e.g. land disposal restrictions).

2Disposition of AFFF that is in its original, unopened packaging (without leaks) must be maintained within the DoW inventory to support operational readiness. See OASW(Sustainment) Memo, Disposition ofAqueous Film-Forming Foam Inventory, dated September 29, 2025, for guidance on disposition of these materials.

HanesKL Cleared address these covered Do W PF AS-containing materials in a comprehensive destruction and disposal approach.

In choosing among destruction and disposal options, one of the most significant factors for Do W is the additional oversight and controls provided at facilities with environmental permits. In issuing this guidance, Do W continues to recognize the statutory authority and responsibility of the EPA and state environmental regulatory agencies to regulate the disposal and destruction ofwastes that may threaten human health or the environment. Additionally, the Do W Components, when selecting options for the destruction or disposal of PF AS-containing materials, must continue to make informed decisions consistent with this guidance.

In choosing among disposal or destruction options included in this guidance, Do W used the following criteria:

• Currently available waste management options for the disposal of large quantities of AFFF and PF AS-containing material;

• Identified options in Do W's 2023 interim guidance or EPA's 2024 interim guidance;

• Options with protections in place to minimize emissions or releases to protect human health;

• Environmentally permitted or regulator-approved options (where permits are not required); and

• The type and composition of PF AS-containing materials requiring disposal or destruction.

While cost was not a screening factor in this analysis, the Do W Components must evaluate the cost-effectiveness of the identified options for disposal or destruction of installation specific PF AS-containing materials, including but not limited to transportation costs. For example, if the PF AS-containing materials are a liquid, the Do W Component should consider if there is an available cost-effective technology that would separate or destroy the PF AS from the liquid to reduce the quantity of liquid that requires disposal. If a technology is not available and cost-effective, the Do W Component should consider which of the options identified below are available and cost-effective, including the costs of solidifying liquids before disposal in a landfill.

The Do W Components, when selecting an option for the destruction or disposal of PF AS containing materials, must continue to make informed decisions consistent with the direction contained in the Attachment to this guidance and the detailed analysis available at www.defense.gov/pfas. Do W has identified the following commercially available options to be used by the Do W Components:

• Carbon reactivation units with environmental permits (for used granular activated carbon only).

• Hazardous waste landfills with environmental permits.

www.defense.gov/pfas

• Solid waste landfills with environmental permits that have composite liners, and gas and leachate collection and treatment systems (not an option for AFFF concentrate).

• Hazardous waste incinerators with environmental permits and that meet specific temperature requirements.

• Underground injection control wells with environmental permits.

• Thermal desorption units that use off-gas collection and thermal oxidation with environmental permits (for soils).

• Other PF AS destruction options with environmental permits or regulator approval where permits are not required, with pre-notification to the Office of the Assistant Secretary of War for Energy, Installations, and Environment (OASW(El&E)).

Do W Components storing PF AS-containing materials for over 90 days before the materials are transported to a destruction or disposal facility shall use onsite hazardous waste storage where available. The Do W Components must continue to make informed, fact-based decisions to mitigate the risk of PF AS releases to the environment for the protection ofhuman health, consistent with the attached guidance.

This guidance supersedes and rescinds the July 11, 2023, memo entitled DoW Interim Guidance on Destruction or Disposal ofMaterials Containing Per- andpolyfluoroalkyl Substances in the United States, along with its corresponding July 14, 2023, memo entitled Guidance on Incineration ofMaterials Containing Per-and Polyfluoroalkyl Substances. This memo authorizes resumption of incineration as an option consistent with the attached guidance.

OASW(El&E) will periodically update this guidance to reflect changes as technologies mature, EPA updates its guidance, and additional data becomes available.

Questions about this guidance should be directed to osd.cleanupandcompliance@mail.mil.

MARKS.DALE Digitally signed by

MARKS.DALE.R. I 080786405

.R.1080786405 Date: 2026.02.20152619-05'00'

Dale R. Marks

Attachment:

As stated mailto:osd.cleanupandcompliance@mail.mil

Attachment - Do W Guidance on Options for the Destruction and Disposal of PF AS-Containing Materials

This guidance applies to disposal and destruction of Department of War's (Do W's) per and poly:fluoroalkyl substances (PF AS)-containing materials being sent to an offsite commercial facility. 3 This guidance does not apply to disposal or destruction of PF AS-containing materials from household or consumer products, or to disposal or destruction of PF AS-containing materials that qualify as hazardous waste under the Resource Conservation and Recovery Act

(RCRA).4

After considering the information in Do W's detailed analysis available at www.defense.gov/pfas, DoW has carefully evaluated the means currently demonstrated to be effective for destroying or disposing of PF AS-containing materials and wastes. In its review, Do W prioritized use of destruction and disposal technologies that have a lower potential for PF AS release to the environment to help support protection ofhuman health and the environment. One important factor was the additional oversight and requirements that are associated with a facility obtaining an environmental permit. Do W also had to consider that most of the PF AS-containing materials that Do W generates are from its aqueous film-forming foam (AFFF) transition, spill responses, or its cleanup program where known PF AS exposures have occurred and are being mitigated and otherwise addressed. Direct human exposures ( e.g., in drinking water that is being addressed under Do W's cleanup program which generates materials for destruction and disposal) had to be balanced against the potential environmental releases from destruction and disposal facilities. Even if releases occur in very small quantities at destruction and disposal facilities, they do not necessarily present any exposure risks to specific populations in the surrounding community. 5 Permitted facilities apply procedures and controls to minimize environmental releases.

3 The guidance does not apply to PF AS remediation treatment technologies, as remedial alternatives are evaluated and selected with environmental regulator involvement and in accordance with the federal cleanup law, the Comprehensive Environmental Response, Compensation, and Liability Act. However, any PF AS-containing waste streams generated from Do W PF AS cleanup actions, that are sent to commercial disposal or destruction facilities (e.g., Granular Activated Carbon (GAC)) used to treat drinking water in a cleanup that must now be regenerated or disposed) would be covered by this guidance.

4 Hazardous waste is regulated pursuant to RCRA authority. See 42 U.S.C. § 6903. The regulatory defmition of hazardous waste is found in 40 CFR § 261.3. PF AS is currently not a listed or characteristic hazardous waste, but a PF AS-containing material may meet the regulatory defmition ofhazardous waste if PF AS is mixed with a listed hazardous waste or if a PF AS-containing mixture exhibits a hazardous characteristic ( e.g., ignitability). Materials that qualify as a RCRA hazardous waste must follow RCRA storage and disposal requirements and are outside of the scope of this guidance. However, for RCRA hazardous waste mixed with PF AS-containing materials, DoW Components shall apply the criteria in this guidance ( e.g., temperature requirements for hazardous waste incinerators) for the disposal or destruction option required by RCRA regulations ( e.g. land disposal restrictions).

See also EPA 2024 Guidance at page 46, footnote 11.

5 See EPA 2024 Guidance at page 1 which states: "While the purpose of an effective destruction and disposal technology is to prevent or minimize environmental releases, it is also important to distinguish between a potential environmental release and a direct human exposure. A PF AS release does not inherently imply direct and immediate human exposure and a release does not necessarily present an unacceptable risk to specific populations."

Do W is therefore identifying the following options, in no specific order, for the Do W Components to use for the commercial destruction or disposal of its PF AS-containing materials, subject to this guidance:

• Carbon reactivation units with environmental permits (for used granular activated carbon (GAC) only). GAC is commonly used to remove PF AS from water. In GAC treatment, PF AS molecules attach to the carbon until the carbon is saturated. Carbon reactivation units use high temperatures to thermally remove contaminants collected in GAC, which allows for the regenerated carbon to be used again. Carbon reactivation units permitted under RCRA and the Clean Air Act (CAA) have additional regulatory oversight, including operating requirements and emission limitations to safely and effectively treat hazardous contaminants.

Do W Components may only use carbon reactivation units with both RCRA and CAA permits.

• Hazardous waste landfills with environmental permits. These landfills have stringent environmental controls in place to manage the migration ofwaste including PF AS into the environment. Permitted hazardous waste landfills employ the most extensive set of environmental controls ( e.g., double liner systems with leachate collection and leak detection) and practices ( e.g., extensive record keeping) that are currently available for the containment ofPFAS waste. In its 2024 Guidance, the U.S. Environmental Protection Agency (EPA) recognized hazardous waste landfills with an environmental permit as one of three technologies that have a lower potential for environmental release of PF AS compared to other technologies in the same category and are viewed as one of the more protective technologies. 6 Do W Components may only use hazardous waste landfills with environment permits. If disposing of liquid wastes ( e.g., AFFF concentrate), the liquid must be solidified to remove free liquids before disposal.

• Solid waste landfills with environmental permits that have composite liners, and gas and leachate collection and treatment systems (not an option for AFFF concentrate). Modem municipal solid waste landfills, when constructed with appropriate controls ( e.g., liner system, leachate and gas collection and management systems, permits), can also control the migration of PF AS into the environment. Do W Components may only use solid waste landfills that have a composite liner, gas and leachate collection and management system and an environmental permit. In addition, based on the type of media, chemical concentrations, and volume of media to be disposed, Do W Components must consider the availability of technologies that may contain PF AS as described in Table 3-4 of the EPA 2024 Guidance. 7 Do W Components are directed to use other

6EPA Interim PFAS Disposal Guidance (Apr. 2024) page 1.

7EPA Interim PFAS Disposal Guidance (Apr. 2024) pages 77-79.

options for the disposal or destruction ofAFFF concentrate and other liquid wastes.

• Hazardous waste incinerators with environmental permits that meet certain temperature requirements. These high-temperature incinerators have stringent regulatory controls on temperature and other operating parameters to achieve a

99.99 percent destruction efficiency for other (non-PF AS) organic chemicals, and evidence suggests that a similar destruction efficiency applies to PF AS-containing materials. In its 2024 Guidance, EPA recognized hazardous waste combustors (e.g., incinerators) with an environmental permit as one of three technologies that have a lower potential for environmental release of PF AS compared to other technologies in the same category and identifies permitted hazardous waste combustors as one of the more protective technologies. 8 As described in Do W's detailed analysis of disposal and destruction options, available at www.defense.gov/pfas, Do W concludes that hazardous waste incinerators that operate the afterburner/secondary combustion chamber at temperatures greater than 1100 degrees Celsius (°C) are adequate to break down PF AS and significantly minimize PF AS emissions. Therefore, Do W Components may only use hazardous waste incinerators with RCRA and CAA permits, operating temperatures greater than 1100 °C in the afterburner/secondary combustion chamber, and that have conducted testing in accordance with EPA's 2024 guidance Appendix A: PFAS Emissions Field Testing at Commercial Thermal Destruction Sources. Do W contracting agencies will require the incinerator to provide a copy of the PF AS Emissions Field Testing documentation that the incinerator submitted to EPA.

• Underground injection control wells with environmental permits. In its 2024 Guidance, EPA recognized underground injection wells with Class I non hazardous industrial waste and hazardous waste wells for high concentration liquid PF AS waste as one of three technologies that have a lower potential for environmental release of PF AS compared to other technologies in the same category and identifies permitted underground injection control as one of the more protective technologies. 9 EPA acknowledged underground injection has the capability to control migration ofPFAS to the environment, but the limited number of these wells currently accepting off-site PF AS liquids may significantly limit the practicality of this disposal option. 10 DoW Components may only use permitted underground injection control wells for liquid waste.

• Thermal desorption units that use off-gas collection and thermal oxidation with Environmental Permits (for soils only). Thermal treatment technologies that utilize a desorption stage have been demonstrated to remove organic

8EPA Interim PFAS Disposal Guidance (Apr. 2024) page 2.

9EPA Interim PFAS Disposal Guidance (Apr. 2024) page 1.

10EPA Interim PFAS Disposal Guidance (Apr. 2024) page 92.

contaminants from soil, sludge, or sediment by heating them to evaporate the contaminants from the solid material and then collect the vapor in a vapor treatment system. Thermal desorption units that use an off-gas treatment system with a thermal oxidizer treat process gases and destroy volatile organic compounds and organic hazardous air pollutants. Thermal desorption is not incineration.

EPA's 2024 guidance indicated that thermal oxidizers are being employed to destroy PF AS-containing and gaseous streams, with some thermal oxidizers being used for halogenated wastes, including PF AS precursors. 11 One or more thermal desorption units with thermal oxidizers have environmental permits and are in use for destruction of PF AS in soils. Therefore, Do W Components, may only use thermal desorption units that use off-gas collection that is treated by a thermal oxidizer and have an environmental permit.

• Other Destruction Technologies with Environmental Permits or Regulator Approval. EPA's 2024 guidance identifies four emerging technologies (mechanochemical degradation, electrochemical oxidation, gasification and pyrolysis, and supercritical water oxidation (SCWO)) that show promise for PFAS destruction, produce few to no hazardous residuals or byproducts, are commercially available, and are cost effective for various impacted matrices. 12

Currently, Do W is aware of only a few non-incineration destruction technologies that have environmental permits or regulatory approval to operate at commercial locations (e.g., SCWO units). In addition to SCWO, other technologies are being demonstrated to address PF AS. Therefore, Do W Components may consider the use of emerging PF AS destruction technologies that have environmental permits or have regulator approval (where permits are not required) and meet any other criteria described in this guidance. A Do W Component that is considering using an emerging technology must follow chain of command procedures to pre-notify the Office of the Assistant Secretary of War for Energy, Installations, and Environment of the selected technology.

11EPA Interim PFAS Disposal Guidance (Apr. 2024) page 52.

12EPA Interim PFAS Disposal Guidance (Apr. 2024) pages 2, 118-127.

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