Insights from the Largest PFAS Disposer in the United States

Managing per- and polyfluoroalkyl substances (PFAS) wastes in accordance with federal and state guidance and regulations is extremely challenging and costly. Attention has been focused on landfilling, incineration, and portable destruction technologies as solutions to manage PFAS waste streams, whereas little focus has been given to Class I hazardous waste injection technology (HWIT; often referred to as “deep well” or “deep injection”). HWIT is a permitted and cost-effective solution for the permanent disposal of complex waste streams including PFAS containing liquids and is a highly effective alternative to PFAS destruction, landfilling, and incineration. Due to the lack of available, credible information on HWIT, the propagation of misinformation and inherent bias across the waste industry has delayed widespread endorsement of HWIT. The goal of this article is to debunk misconceptions and clarify outdated information on HWIT by sharing credible information from the largest-by-volume treatment, storage, and disposal facility (TSDF) in the United States so informative, data-driven decisions are made to responsibly manage PFAS wastes. 

VLS Texas Molecular Deer Park (TMDP) is the largest-by-volume TSDF in the United States and disposes ~25 million gallons of PFAS liquids per year using HWIT. TMDP injects PFAS fluids ~7,500 feet below ground surface (ft bgs) into a confined frio sand formation, far beneath drinking water resources. Extremely-low, permeable shale over 500 ft thick protects the overlying underground source of drinking water (USDW) from the underlying frio sand formation (the lithology of Texas is well mapped due to petroleum exploration). Because the confined frio sand geologic formation lies outside Earth’s biosphere, injected waste will not impact drinking water aquifers nor pose a risk to human health and ecological receptors.

EPA issued a 10,000-year No Migration Petition (NMP) to TMDP because EPA concurs that injected fluids will not migrate outside the injection zone (frio sand formation; ideal geological formation for the injection of complex waste streams) for at least 10,000 years and injected fluids will not adversely impact an USDW [40 CFR Part 148]. This NMP is granted only to HWIT facilities which is a key distinguishing factor that separates HWIT (most stringent classification) from non-HWIT. HWIT facilities are also not subject to RCRA land disposal restrictions (LDRs; 40 CFR Part 268); therefore, injected fluids are not required to meet treatment standards (concentration-based or technology-based). To maintain the NMP, NMP holders must periodically redemonstrate to EPA that injected wastes remain confined in the formation [40 CFR Part 148].

TMDP injects approximately 130 million gallons of its annual 236-million-gallon injection capacity. In 2025, TMDP had nearly 100 million gallons of excess annual capacity. This fact invalidates the common misconception that HWIT capacity is limited as published in Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl Substances and Materials Containing Perfluoroalkyl and Polyfluoroalkyl Substances (EPA 2026) and Updated Interim Guidance on Destruction or Disposal of Materials Containing Per and Polyfluoroalkyl Substances in the United States (Department of War [DoW] 2026). TMDP is located in Texas, and this fact should not be construed as a geographic limitation because transportation and logistical challenges are no different than shipment of PFAS liquids to the limited number of Subtitle C landfill and regulatory approved incinerators across the United States. TMDP has accepted and injected wastes from all regions of the United States using HWIT and has partnered with large commercial airlines to dispose millions of gallons of PFAS liquids and aqueous film-forming foams (AFFF). 

HWIT provides many exceptional benefits to generators that are not offered by other PFAS disposal/destruction/treatment options. The key benefits of using HWIT to responsibly manage PFAS liquids are highlighted as follows:

TMDP has disposed over 2.5 billion gallons of hazardous and non-hazardous waters (including PFAS and AFFF) containing hundreds of unique chemicals/constituents from the biosphere during its 40+ years of operation. TMDP’s key permits/credentials are as follows:

As federal agencies, DoW, state regulators, and private industry continue investing billions of dollars in PFAS remediation, PFAS management options should be guided by facts, regulatory rigor, and demonstrated performance rather than misconceptions. HWIT is a proven, highly regulated, and scalable disposal option available today. An understanding of HWIT is essential for decision makers to make informed, technically defensible decisions that protect human health and the environment while supporting cost-effective and timely project execution. 

For potential clients, regulators, and federal decision makers interested in learning more about HWIT, using our services, and/or securing a TMDP tour, please email info@vlses.com or dial (877) 861-8588.