Giant chemical companies who have produced per- and polyfluoroalkyl substances (PFAS) - known as “forever chemicals” due to their persistence in bodies and the environment - have set aside $4 billion dollars to pay for their expected liability for cleaning up that historic contamination. Yet at the same time, these companies (including Chemours, 3M and DuPont) and dozens of other industries, continue to produce and use closely related chemicals with very little government oversight. The persistence and mobility of PFAS chemicals - poses an incredible challenge for waste disposal. Yet, there are virtually no monitoring and reporting requirements for PFAS emissions from factories and even fewer restrictions about how to dispose of PFAS chemical wastes.
Frequently, PFAS chemicals are disposed of in landfills and deep disposal wells, yet these structures aren’t necessarily designed to be secure for the length of time that PFAS will persist in the environment. The chemicals’ intense thermal stability and reactivity means that they are not fully destroyed in incinerators. PFAS are flushed into wastewater, and waste sludge is spread on land while liquid waste is released back into rivers. Therefore, instead of eliminating contamination, current PFAS disposal practices perpetuate the harmful cycling of PFAS in the environment.
To make matters worse, disposal sites like dumps, incinerators, and injection wells are located on or near historically “red lined” communities of color or on Tribal lands. As money is earmarked to clean up PFAS contaminated water and soil, it is essential to ensure that wastes are safely contained or destroyed instead of simply concentrating the pollution in historically burdened communities.
We’ve gleaned through the sparse data on the movement of PFAS wastes to identify the 10 worst methods for disposing of PFAS:
Put it into the air
🔥 #1 Burn PFAS-based industrial fire fighting foams in hazardous waste incinerators.
The US Department of Defense (DOD) contracted to incinerate millions of gallons of unused high temperature fire fighting foams, known as AFFF, despite the fact that it had no proof that incineration is an effective or safe disposal method. Through Freedom Of Information Act requests, we learned that the DOD waste was largely sent to historically burdened incinerator communities in Cohoes, New York, Arkadelphia, Arkansas and East Liverpool, Ohio. While Congress has put in place a temporary moratorium on incineration of PFAS by the DOD, studies (including the Nc non target study) show that unidentifiable fluoro-chemicals are passing out of incinerator stacks.
🏭 #2 Use PFAS-based as “fuel” at incinerators that make energy, aluminum, cement, or aggregate.
Data is sparse but through the first year of mandated reporting under EPA’s new Toxics Release Inventory (TRI) rules, we learned that one cement plant, Buzzi Unicem’s Greencastle Plant in Indiana burned 12,000 pounds of PFAS waste in 2020. Prior to TRI rules taking effect, Rhode Island and Massachusetts collected about 20,000 gallons of PFAS-based AFFF firefighting foams and sent the foam to a commercial fuel-blending facility in Ohio where it was blended into fuel. The products were ultimately incinerated in Covanta Waste-to-Energy facilities in Indianapolis, Indiana, or Niagara, New York. In addition to incinerators, millions of gallons of US military foams were sent to fuel blending facilities, including six sites which received between 200,000 and 2,000,000 pounds each of AFFF waste.
💥 #3 Explode it!
US Ecology in Beatty, Nevada used “open detonation” to dispose of nearly 40,000 pounds of PFAS-containing waste. Open detonation has long been a concern for veterans and people who live near military waste sites because it spews waste materials directly into the air; the presence of PFAS in munitions only makes this bad situation worse.
🔥 #4 “Regenerate” used carbon filters by heating them to release PFAS and other compounds into the air, without ensuring destruction.
Water filter systems use activated carbon and ion exchange filters to remove PFAS and other harmful chemicals. When the filters are clogged with chemicals, they can be sent to thermal furnaces to be “regenerated” or “reactivated.” Similar to incinerators, these furnaces use heat to vaporize PFAS and other contaminants from the filter material. As with all heat-based treatments, there are major gaps in public knowledge about whether PFAS are destroyed or just transformed into other harmful compounds that escape as waste gasses.
According to their RCRA and Air permits, one major water filter company, Evoqua, has one of its regeneration facilities on Colorado River Tribes Reservation in Parker, Arizona, where they heat spent carbon filters in a high-temperature "regeneration" furnace. The facility does not have to test air emissions for PFAS, claiming there are no standards for this and that PFAS are not listed in EPA’s national hazardous waste laws. Evoqua’s processed wastewater is sent to the Parker treatment plant, which drains into the Colorado River. As drinking water treatment ramps up, we must ensure that companies like Evoqua, Calgon, and Suez, have plans to safely contain used filters or can prove that heat-based regeneration systems fully destroy PFAS compounds.
Dump it into the water
💧 #5 Wash PFAS down the drain.
Only a handful of states have set any limits on PFAS discharges into the wastewater system. Yet certain industries - like airports, refineries, metal plating, textiles, paper, and fire training sites - are sources of pollution as PFAS washes down the drain into wastewater and stormwater collection systems. Michigan has the most advanced programs to identify and control PFAS discharges from highly polluting industries, and the result is far less PFAS in wastewater, biosolids, and effluent that passes back into the environment. However, most states haven’t done anything to quell the dumping of PFAS into the wastewater system.
🚰 #6 Remove PFAS from drinking water and release waste back in the river.
Reverse osmosis is one of the most effective technologies for removing PFAS from drinking water, particularly newer generation chemicals which can evade carbon filtration. Unfortunately RO systems produce wastewaters that contain all the filtered out pollutants, and these are often discharged back into streams and other bodies of water. RO systems are used to provide clean drinking water in several U.S. communities that have been heavily impacted by PFAS production. But as a long term solution this tool doesn't reduce the burden of PFAS pollution for the local ecosystem..
💦 #7 Inject liquid wastes into deep wells.
All sorts of liquid wastes are injected into deep wells for disposal. Wells fail when steel and cement shaft linings fracture or degrade over time. But there is little monitoring and no way to safely recover injected materials. An investigation by ProPublica of 220,000 well inspections from 2007 to 2010 found that well integrity violations were issued for one in six deep injection wells examined, and more than 7,000 of the wells inspected showed signs of leakage. Many of the wells certified to receive hazardous waste are located in Texas, where EPA estimates that more than 50 million gallons of PFAS-containing waste have already been injected.
Put it on the ground
🚜 #8 Concentrate PFAS waste from wastewater into sludge and spread it on agricultural lands and home gardens.
There are virtually no restrictions on PFAS discharges to wastewater systems when the chemicals accumulate in the solid materials that settle out in the treatment process. The states of Maine and Minnesota have both tracked contaminated crops, meat, and dairy products in fields where these contaminated sludges or “biosolids” have been applied as a fertilizer. The Sierra Club and the Ecology Center also measured similar amounts of PFAS in sludge-based home fertilizers sold at big and small retailers. Recently we’ve learned that PFAS-contaminated industrial wastes from at least one large leather tannery were also spread on agricultural lands under Michigan’s interpretation of national “beneficial reuse” laws which aim to keep wastes out of landfills.
🚛 #9 Bury it in a landfill.
Landfills aren’t designed to last forever, but PFAS are. As a result of their persistence and mobility, PFAS easily escape from landfills into the air or leak out of the lining systems, and are frequently detected in ground and surface water and liquid waste that leak from historic and active landfills. New York, Minnesota, and Vermont have all measured PFAS at virtually every landfill they test, yet waste managers continue to send PFAS-contaminated materials to landfills. In 2019, the Short Terminals fuel storage tank farm caught fire in Crockett, California, (adjacent the San Francisco Bay), and the company captured the petroleum- and PFAS-contaminated wastewater from fire fighting in large ponds. After examining its disposal options, it opted to ship tanker trucks of contaminated water to US Ecology in Beatty, Nevada, where the wastes were mixed with clay and deposited in a Class 1 (non-hazardous waste) landfill.
When all else fails, simply send it away… Preferably to a place with less oversight.
🌎 #10 Export waste to a country where rules are weaker.
For several years, Chemours shipped its PFOA-replacement GenX waste from the Netherlands back to North Carolina for disposal. In 2019, Chemours imported an estimated 90 million gallons of industrial waste containing GenX for recycling. Much of the liquid waste was sent to Port Arthur, Texas, for deep well injection. This material is regulated as a hazardous waste in the Netherlands but not presently listed in the US. It appears that US wastes as well as PFAS-contaminated biosolids have been sent to landfills and incinerators in Canada, which also has not listed this liquid waste as hazardous.
🙌 Better solutions are in our grasp 🙌
EPA is pursuing listing of two PFAS chemicals, PFOS and PFOA, under the Resource Conservation and Recovery Act (RCRA), and pledges to consider controls on disposal of other chemicals in the category. But these listings won’t come quickly enough and could ultimately green-light unsafe disposal practices.
Clearly a safe management system would curtail the ongoing production and use of PFAS in industrial processes and hold chemical companies responsible for the massive crisis of PFAS contamination. Presently, landfills, wastewater systems, and other industries are concerned about the liabilities they could face for pollution they didn’t create or profit from.
Meanwhile, promising technologies are in development that can fully destroy PFAS using heat, pressure, microbes or other forces. These systems should be fully contained and use monitoring to ensure they achieve high levels of effectiveness. Congress has placed a moratorium on the incineration of PFAS waste by the US military. At least three states - California, Colorado and Washington - are holding waste foams until safer disposal options are available. This pause is necessary as alternative destruction technologies are developed and scaled to address stockpiles of millions of gallons of unused and highly toxic PFAS-based fire fighting foams. These systems can also be effective for smaller scale or dispersed wastes like sewage sludge, highly contaminated soils, landfill leachate and other contaminated materials.