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.
723
DOD installations requiring PFAS assessment
$9.3B+
Estimated future cleanup costs (FY2025+)
2M gal
Legacy AFFF stockpile being managed
1.5M gal
PFAS-contaminated equipment rinsate
1,000+
Facilities transitioning from AFFF to F3
6,800+
Mobile assets requiring foam system replacement
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
Impact on nearby water systems: Water utilities near military bases should note that DOD cleanup timelines are being extended significantly (e.g., Fairchild AFB: 2026 → 2032; Whidbey Island → 2034). Contamination will persist longer than originally projected. 55 installations have PFOS/PFOA above 70 ppt in nearby drinking water.
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
Approved
Incineration 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
Approved
Hazardous waste landfills with double composite liners and leachate collection systems remain a viable disposal option for PFAS-containing solids and concentrated liquids.
Acknowledged 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 recommended
Dropped 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
EPA MCLs (retained)
4 ppt
PFOA and PFOS — unchanged
Compliance deadline
2031
Extended from 2029
DOD interim action trigger
3x MCL
PFOA 12 ppt, PFOS 12 ppt in private wells near bases
Scope change
Narrowed to PFOA/PFOS
EPA rolled back limits on other PFAS from 2024 rule
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