The Environmental Protection Agency (EPA) recently released updates on its interim guidance for the destruction of PFOS (perfluorooctane sulfonate) and other PFAS (per- and polyfluoroalkyl substances) materials. David Trueba, President and CEO of Revive Environmental, shared his perspective on these updates and their impact on airports.
According to Trueba, Revive Environmental has been preparing for these changes since 2018, when the company envisioned a set of standards for PFAS disposal.
"When Battelle started the journey of creating the technology and then the eventual spin-off [of Revive], this was always the goal," Trueba said. "So, we're really pleased about the guidance."
The new guidance from the EPA provides more information on disposal methods, including potential questions regarding the long-term viability of options such as landfill deep well injection and incineration. Trueba notes that the EPA also introduces a technology evaluation framework that requires airports to assess various disposal methods.
"As an airport operator, they're going to need to take a holistic approach around sourcing new foam that's responsible and at the mill spec," Trueba explained. "How do you maintain airport operations during the transition and most importantly, to avoid liability in the future? They need to choose their disposal method properly."
Trueba advises airport operators to carefully consider their disposal options and make informed choices to minimize environmental and economic harm. He emphasizes that Revive Environmental's services align with the EPA's criteria for proper disposal of PFAS materials and have been operating according to the EPA's standards for the past year.
Regarding the challenges airports may face with the updated guidance, Trueba does not see any significant new obstacles.
"The guidance, again, for incineration, landfill, and deep well really didn't change except for they have more questions now about those in terms of the data effectiveness," Trueba said. "So, I do think there is maybe a challenge on making sure that they truly understand those options."
The Environmental Protection Agency's (EPA) new PFAS disposal guidance comes just before significant changes to the maximum contaminant levels (MCL) for drinking water. Trueba points out that this timeline is crucial for understanding the broader implications for airports and other facilities dealing with PFAS disposal.
"The Clean Water Act dictates through congressional legislation what standards can be held to for any municipal drinking water facility in the country," Trueba explains. "Those standards have now been established, and they have to be in compliance in five years." This means airports and other facilities must adhere to much more stringent discharge standards than in the past.
Trueba uses the example of an airport in Riverside County, California, to highlight how these changes impact operations at the local level. In the past, the airport could discharge to a local landfill, but now the standards for disposal are more stringent. "The bar for discharge has just gotten incredibly high," Trueba notes. "Those levels are very low, very stringent for drinking water, and now they can be the standard for disposal."
The combination of new disposal guidance, maximum contaminant levels for drinking water, and soon-to-be-released hazardous designations for PFOS substances under RCRA and CERCLA is expected to have a significant impact on how airports and other facilities approach disposal. These changes will determine the cost and process for treating these materials as hazardous substances.
Trueba advises airports to prepare for the transition, noting that no fluorinated foams will be produced by major manufacturers like Tyco and National Foam after July 2025. "The sooner, the better would be advisable," he recommends. Revive Environmental has already been treating airports, with recent clients such as Cedar Rapids Airport opting for their services.
