Day 2 6 PFAS Construction and Best Management Practices

Air Force Installation & Mission Support Center

Best Management
Practices for
Addressing PFAS at
Construction Sites
Mahalingam Ravichandran, PhD
AFCEC PFAS Integrator

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Overview Topics
 Background
 Regulatory Framework
 Dept of War Guidance and Policies
 Dept of Air Force Best Management Practices
 Planning and Programming Phase
 Design and Construction Phase

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Background
 Widespread occurrence of PFAS at many construction sites from historical

AFFF releases, high GW mobility, low screening levels
 Major impacts on cost/schedule of Military Construction (MILCON) and

Facilities Sustainment, Restoration, and Modernization (FSRM) projects, affecting mission readiness
 MILCON Projects programmed years back when PFAS was not an issue  No clear disposal standards or cost-effective disposal options  MILCON/FSRM use different funding and timelines than DERP cleanup

 March 2025 SAF/IEE issued BMPs to avoid, minimize, or manage excavated

soil/groundwater impacted with PFAS and other contaminants at MILCON/FSRM sites

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Regulatory Framework
 DoW conducts environmental cleanup of PFAS under CERCLA  Use of Regional Screening Levels for soil/groundwater to determine whether further investigation is needed – RSLs are NOT disposal standards  PFOA and PFOS are listed as CERCLA hazardous substances  SDWA (MCLs) – applicable to Public Water Systems, not construction sites  RCRA – not a regulated waste (listed or characteristic)  9 PFAS chemicals were proposed as hazardous constituents under RCRA; it’s unknown if EPA intends to finalize those rules
 State Standards
 Some states have promulgated PFAS standards for groundwater, surface water, soil etc.  States may have screening levels for soil management, waste disposal

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DoW Guidance / Policies
 Jan 2026 Guidance for MILCON projects w/ Historical Contamination  Planning Phase
 Collaboration between planning & env. staff (e.g., use PFAS scoping checklist)  Baseline sampling prior to site selection, cost for treatment/disposal in DD 1391  Use Geospatial data to identify contaminated area, LUCs, and in Master Planning

 Construction Phase – Management of Impacted Media
 Dewatering – meet CWA standards, discharge permits
 Soil – temporary stockpile need engineering and erosion controls

 Feb 2026 Updated Interim Guidance on Destruction or Disposal