Industrial-Strength Solutions
Langan Helps Clients Navigate PFAS in Industrial Operations
Valued for their physical and chemical versatility, PFAS are widely used in industrial applications as lubricants, surfactants, fume suppressants, adhesives, sealants, coatings, cable and wire insulation jackets, and more. The United States Department of Defense recently published a report highlighting the critical need for continued use of PFAS despite their documented persistence and unknown impacts on human health and environmental receptors. Many companies likely also consider PFAS indispensable to operations due to the absence of alternative options with similar cost and efficacy.
However, unlike the organic counterparts and predecessors of PFAS, which degrade over time, the persistent use of PFAS compounds implies that they remain in the environment after being used in industrial applications, either at the point of use or elsewhere. As a result, PFAS waste may be more prevalent than expected, highlighting the need for proper management and disposal. This also raises the possibility that PFAS may be encountered in unexpected places.
Required under the National Defense Authorization Act of 2020, EPA publishes interim revised guidance on PFAS destruction and disposal every three years, with the latest published in April 2024. Options for destruction and disposal are limited to thermal treatment, landfill disposal, and underground injection:
– Thermal treatment involves the combustion of PFAS into carbon dioxide and hydrogen fluoride. Operating conditions and controls for this treatment vary across device types and designs to achieve high destruction efficiencies and low incidence of incomplete combustion by-products, though they consistently require extreme temperatures and lengthy residence times.
– Landfill disposal, the most common method, involves the containment of PFAS on land, and management techniques and controls vary to mitigate offsite releases through leachates and gases resulting from decomposition.
– Underground injection involves confining concentrated liquid PFAS waste into suitable geologic formations, limited by resource availability and subsurface transport unpredictability.
As of July 2024, PFAS are regulated as hazardous substances at the federal level under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). They are not considered hazardous waste under the Resource Conservation and Recovery Act (RCRA), though recent steps have been taken toward their incorporation under RCRA. In February 2024, EPA published a proposed rule—with initial plans to publish as final in July 2025—adding nine PFAS to the RCRA list of hazardous constituents. While the final rule has not been published and its progress is uncertain, this designation would stipulate additional management requirements for those PFAS, such as time and volume accumulation restrictions.
Amid ongoing uncertainty, Langan is helping clients track PFAS regulatory status changes, mitigate liability, and assess process and waste streams in industrial applications to identify and characterize PFAS in anticipation of evolving regulations. The firm’s subject matter experts conduct the full spectrum of PFAS services, from desktop reviews to full compliance audits of treatment and disposal facilities for historical compliance and available technologies. By providing information and actionable recommendations to clients, they can seek disposal options while minimizing risk. Langan also supports clients with completing regulatory submissions, such as Toxic Release Inventory reports, which include determining the ultimate disposition of PFAS compounds used in industrial processes.
As advancements are made in available PFAS treatments and disposal technologies, and knowledge grows regarding the effects of PFAS, regulations are expected to change. Those who rely on PFAS, whether in industrial applications or elsewhere, must diligently characterize PFAS in process and waste streams, as this information is crucial to informing proper management and limiting liability in the future.
Learn more about Langan’s PFAS analysis and consulting services.
Katie Childs is a Senior Project Manager in Langan’s Cleveland office with over 12 years of experience in the environmental industry, focused primarily on multimedia regulatory compliance. Her expertise covers environmental permitting and compliance at heavy industrial sites across the United States, including foundries, machining, and electroplating facilities. She also specializes in ASTM Phase I assessments, subsurface investigations, indoor air quality sampling, and noise monitoring.
Aislen Kelly is a Senior Staff Scientist with four years of experience in environmental permitting and compliance. Located in Langan’s Boston office, she specializes in providing multimedia compliance support for a range of industrial clients, helping identify and address any initial or ongoing compliance obligations. Kelly’s expertise includes state and federal programs, including CAA, CWA, CERCLA/Superfund, RCRA, and EPCRA.