DOD updated PFAS guidance: disposal options, AFFF phase-out & military base cleanup
The Department of Defense published updated interim guidance on the destruction and disposal of PFAS-containing materials, covering 723+ installations and an estimated $9.3 billion in future cleanup costs. Key changes: solid waste landfills dropped as viable, incineration moratorium lifted, and AFFF phase-out deadline set for October 1, 2026.
AFFF phase-out: October 1, 2026
DOD must stop purchasing PFAS-containing aqueous film-forming foam (AFFF) by October 1, 2026 (extended from October 2024 via waiver). The transition to fluorine-free F3 alternatives involves approximately 1,000 facilities and 6,800+ mobile assets.
Transition challenges
- No standard practice exists for effectively removing PFAS residue from pumps, tanks, trucks, and hangar suppression systems — entire foam delivery systems may need replacement
- F3 foam is 21% more costly than AFFF, creating ongoing budget implications
- DOD is managing approximately 2 million gallons of legacy AFFF and 1.5 million gallons of PFAS-contaminated equipment rinsate
- DOD has invested $160M+ through FY2022 with another $60M through FY2025 and supports 200+ technology development/demonstration projects
PFAS disposal methods: what's approved
DOD's 2026 interim guidance evaluates four disposal pathways. The biggest change: solid waste (municipal) landfills are no longer recommended after EPA found they release more PFAS than previously estimated.
Hazardous waste incineration
ApprovedIncineration moratorium lifted. Permitted hazardous waste incinerators may accept PFAS-containing materials provided air quality regulations are met.
Key considerations: Must meet Clean Air Act requirements. Stack emissions monitoring required. Community opposition may delay permitting.
Hazardous waste landfills
ApprovedHazardous waste landfills with double composite liners and leachate collection systems remain a viable disposal option for PFAS-containing solids and concentrated liquids.
Key considerations: Limited capacity nationally. Transportation costs significant for remote installations.
Deep well injection
LimitedAcknowledged as technically viable but DOD notes it will rarely be an available option due to logistical difficulty and limited wells accepting offsite PFAS waste.
Key considerations: Few Class I injection wells accept PFAS waste. Transportation logistics complex. Not practical for most installations.
Solid waste (municipal) landfills
No longer recommendedDropped from DOD guidance. EPA found that municipal solid waste landfills release more PFAS to the environment than previously estimated, even with composite liners and leachate collection.
Key considerations: Previously considered viable in 2023 guidance. Change driven by updated EPA destruction and disposal analysis.
Emerging PFAS destruction technologies
DOD is funding 200+ technology development and demonstration projects. These emerging methods may supplement or replace traditional disposal pathways as they mature.
| Technology | Target | Readiness | Detail |
|---|---|---|---|
| Supercritical water oxidation (SCWO) | Liquids (AFFF, rinsate) | Demonstration | High pressure + heat destroys PFAS molecular bonds. DOD-funded demos show promise for on-site treatment of legacy AFFF stockpiles. More efficient and cost-effective than off-site disposal. |
| Mechanochemical degradation (ball milling) | Soils, solids | Demonstration | Mechanical force breaks PFAS bonds in contaminated soil. Avoids thermal treatment. Being evaluated for in-situ soil remediation at military installations. |
| Electrochemical oxidation | Liquids | Pilot | Electric current drives PFAS destruction in contaminated water. Lower energy requirements than SCWO. Being evaluated for treatment of dilute PFAS streams. |
| Gasification and pyrolysis | Solids | Pilot | Thermal conversion of PFAS-containing solid waste under controlled conditions. Potential for energy recovery. Early-stage evaluation. |
Updated MCL thresholds & compliance timelines
What this means for you
Water utility operators
- DOD is sampling drinking water off-base near military installations — 55 have PFOS/PFOA above 70 ppt
- DOD will initiate interim actions for private wells where PFAS exceeds 3x MCL (PFOA/PFOS: 12 ppt)
- Cleanup timelines are being pushed out significantly — plan for contamination to persist longer than projected
- Extended EPA compliance deadline (2031) gives more time but means prolonged exposure risk for systems near bases
Remediation contractors
- 723 installations require assessment — 586 are proceeding to the next CERCLA phase
- $9.3B+ in future investigation and cleanup costs (FY2025+)
- AFFF-to-F3 transition at ~1,000 facilities — no standard practice for removing PFAS from delivery systems, creating demand for specialized decontamination services
- $407.8M secured in FY2026 defense funding for PFAS cleanup (Sen. Murray)
Environmental consultants
- New state PFAS laws in 2026: Colorado, Maine, Connecticut, Vermont, Minnesota, Illinois, New Mexico
- Gap between EPA federal MCL (4 ppt) and some state standards requires advising on the stricter applicable standard
- Congressional proposals to cut DOD cleanup budgets could shift more burden to state programs
- Minnesota PRISM (PFAS Reporting and Information System) reports due July 1, 2026 — advisory demand for manufacturers