The federal and state landscape of per- and polyfluoroalkyl substance (PFAS) regulation is changing very quickly. For facilities that have used PFAS-containing materials, it may seem like the only way you can keep up is to have a crystal ball. That’s why, if you’re thinking about decommissioning and the decontamination that goes with it, now is the time to engage a consultant and develop a strategy. Anticipated changes to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Resource, Conservation, and Recovery Act (RCRA), and state regulations could make decommissioning activities more difficult in the future. Here, we explore six areas to consider when forming your decommissioning strategy.
1. Risk identification
In identifying the risks you may face in decommissioning your facility, you will need to consider common PFAS sources and determine how they will impact your property/project. Common sources of PFAS—including roofs, stormwater ponds, insulation, concrete floor sumps, and AFFF and other fire suppressants—may impact the environment surrounding your facility. Because PFAS is ubiquitous in the environment, field detection or grab samples may not be sufficient to accurately determine your risk. A comprehensive sampling plan combined with quantitative analysis will better define the risk, but it takes time for labs to process and report your results.
2. Future site alternatives and liability tolerance
For PFAS-impacted facilities, you will want to think about alternatives for future site use, which can affect decontamination activities. It’s equally important to determine the organization’s PFAS liability tolerance by assessing where and how the demolition debris and waste materials will be managed, the impact to the organization’s image with the local community, and the risk of residual PFAS after the decommission is complete.
3. Closure standards
Closure standards can come in different forms. There are no closure standards for facilities not regulated under the RCRA. However, facilities considering decommissioning should check zoning codes, conditional use permits, and any applicable local requirements. RCRA facilities will need to abide by requirements for blasting concrete and washing process equipment. A well-planned approach to decommissioning and decontaminating that follows industry standards, such as the American Society for Testing and Materials (ASTM) PFAS standards and bench testing, is essential to successfully negotiating cleanup standards.
When planning implementation, consider what support will be available. Will operations staff be available for support, or will the decommissioning occur after operations cease? What is involved in ceasing operations? Are you required to take steps to make the facility stable, such as disconnecting the power and water, or will you maintain the utilities at a cost? Will environmental remediation require long-term groundwater recovery and treatment?
5. Waste management and risk profile
You should also think about the likelihood of the waste being accepted at disposal facilities. Does a nearby recycler have PFAS destruction facilities on site? What about decontamination water disposal: will you treat it or send it to an incinerator? If using a landfill, will it be subtitle C or subtitle D? What is the landfill’s long-term plan for management of generated leachate? It’s important to account for the processing necessary for disposal facility waste acceptance. Disposal facility processing requirements (i.e., sizing requirements) can turn into significant hidden PFAS demolition costs.
6. Financial considerations
Where financial considerations are concerned, uncertainty surrounding cost estimation for decommissioning stems from three elements. First, as mentioned above, on-site processing of materials for offsite management can vary greatly in cost, which is amplified if union labor is involved. Selective demolition and segregation are labor-intensive without cost history for benchmarking. Second, offsite disposal pricing changes frequently, and there are potential hidden costs. Third, soil cleanup, if applicable, can add considerable cost.
A comprehensive decommissioning plan is important for identifying risks to be managed. Once you know the levels of PFAS, you can approach waste management and recycling facilities confidentially to learn their acceptance criteria. These may include the co-disposal of other regulated materials (e.g., PCB and asbestos), demolition debris, and soil potentially impacted with RCRA waste in addition to PFAS.
PFAS-related rules and regulations are changing, causing waste management acceptance criteria to change quickly too. This can make waste management during decommissioning, decontamination, and demolition of a site complicated and difficult, so it’s important to request the acceptance requirements and costs in writing from your disposal vendor.
Contact our team of PFAS experts for additional information or learn more about Barr’s PFAS services.
About the author
Joe Berns, vice president, senior engineer, has 27 years of experience as a project manager and engineer for industrial and remedial projects, including planning, scheduling, cost estimation, contracting, design, specification, preconstruction, and construction management. Joe has led PFAS decontamination and decommissioning efforts at a large confidential RCRA industrial facility, including workplan preparation, establishing performance standards, sampling and analysis planning, and quality control planning. In addition, he has led the assessment of PFAS uses and potential liability costs for confidential manufacturing facilities.