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Industry Perspective · 2026
By
, Research & Reference Desk
June 25, 2026
TL;DR
The U.S. Department of Defense has identified PFAS contamination at more than 700 active and former installations, with the 2020 NDAA mandating AFFF phase-out by October 2024 and the EPA's April 2024 final PFOA/PFOS drinking water MCLs at 4 nanograms per litre. The Canadian Department of National Defence portfolio adds hundreds of additional bases and former defence properties under the Federal Contaminated Sites Action Plan.
Landfill is not a permanent answer for PFAS on either side of the border. Leachate carries the contamination forward, monitoring runs in perpetuity, and the regulatory direction across U.S. CERCLA designations, EPA MCLs, Canadian CEPA Schedule 1 (2025), and the Stockholm Convention is converging on destruction.
The defining capability for a credible PFAS destruction contractor across North America is an owned mobile high-temperature destruction fleet operating above carbon-fluorine bond rupture temperatures, with independently verified destruction-and-removal efficiency, and a cross-border deployment history to operationally sensitive sites.
Nelson Environmental Remediation carries all three, with PFAS at pilot and test-bed stage: the RS-series operating envelope is engineered for PFAS, the NATO PFAS Treatment Technology Test Bed selection documents the chemistry, the American Samoa and Vietnam programmes document the deployment capability to legacy military and defence-adjacent sites, and the platform mobilises routinely across the Canada-U.S. border.
Aqueous film-forming foam (AFFF) was the standard firefighting agent at North American military airfields, hangar fire-suppression systems, fuel-handling facilities, crash-rescue stations, and fire-training grounds for approximately five decades. It worked. It also deposited per- and polyfluoroalkyl substances (PFAS) into soil and groundwater at every site where it was used. In the United States, the Department of Defense has identified known or suspected PFAS releases at more than 700 active and former installations across all 50 states under a portfolio-wide investigation triggered by the 2020 National Defense Authorization Act. In Canada, the Department of National Defence has documented PFAS impacts at a comparable proportion of its installations under the Federal Contaminated Sites Action Plan. The combined inventory is large enough that the relevant procurement question is no longer whether destruction-based remediation will be required, but who can credibly execute it at scale across both jurisdictions.
This article is a working read of that procurement question for technical leads, environmental managers, base remedial project managers, and DoD and DND programme officers writing PFAS remediation specifications over the next several years. It sets out the regulatory frame on both sides of the border, the reason landfill has become a deferred liability rather than a closure, the destruction technology comparison, the verification requirements that separate marketing from capability, and the deployment record that demonstrates a contractor can actually execute at a defence installation rather than only describe how it would.
The PFAS procurement question has shifted from whether to destroy to who can prove they have destroyed it, on a site that looks like the next one, under the regulator that signs off on the next closure.
PFAS impacts at North American military bases trace primarily to AFFF use at fire-training areas, hangar suppression systems, crash-rescue stations, and bulk fuel facilities. The same pattern appears at almost every major airfield in both countries and at most former installations, and it is mirrored at municipal and regional airports that ran parallel training and suppression programmes.
On the U.S. side, the Department of Defense PFAS investigation under the 2020 NDAA has now identified more than 700 active and former installations with known or suspected PFAS releases, and the AFFF phase-out for shore-based use was required by October 2024. The U.S. EPA designated PFOA and PFOS as CERCLA hazardous substances in 2024, which extends Superfund authority and cost-recovery exposure to PFAS releases, and the EPA's April 2024 final National Primary Drinking Water Regulation set enforceable Maximum Contaminant Levels of 4 nanograms per litre for PFOA and PFOS, with individual MCLs for PFNA, PFHxS, and HFPO-DA, plus a Hazard Index for mixtures. Those numbers reset the closure target for every groundwater plume at a base boundary.
On the Canadian side, the Government of Canada added the PFAS class to Schedule 1 of the Canadian Environmental Protection Act in 2025, framing PFAS as toxic substances requiring management toward destruction. Health Canada's drinking water guideline for the sum of PFAS is 30 nanograms per litre. Canada is a Stockholm Convention party, and the Convention's direction on long-chain PFOS, PFOA, and PFHxS favours destruction over containment for unintentional and legacy sources. Provincial contaminated-sites programmes, including Alberta Tier 1 and Tier 2, British Columbia's Contaminated Sites Regulation, and Ontario Regulation 153/04, are publishing PFAS values and aligning closure pathways with the federal direction.
The two regulatory environments are not identical, but they are converging on the same procurement reality: containment defers the liability, destruction closes it.
The default response to PFAS-impacted soil at many sites has been excavation and transfer to a permitted landfill. The problem with that response is that PFAS does not stay in the landfill. Carbon-fluorine bonds are among the strongest in organic chemistry, which is why PFAS persists in the environment, and the same persistence applies inside a landfill cell. PFAS leaches into landfill leachate, which is then trucked to wastewater treatment plants that were not designed to remove it, and which therefore discharge it to receiving waters. The contamination is moved, not destroyed. Monitoring obligations attach to the original site, the receiving landfill, the leachate stream, and the discharge point, and run in perpetuity. Under CERCLA's 2024 PFAS hazardous-substance designation, that perpetual chain becomes perpetual cost-recovery exposure.
The argument for permanent destruction over landfill transfer is set out in detail at Why Contain and Monitor Is No Longer Enough, and the PFAS-specific chemistry case is at Fighting Back Against Forever Chemicals.
Several destruction pathways have been proposed and piloted for PFAS. Each carries a different combination of throughput, verification maturity, and field deployability. The comparison that matters to a DoD or DND site owner is the comparison across all three dimensions at once, not any single one.
High-temperature thermal destruction. Mobile thermal desorption with a high-temperature secondary oxidiser is the most field-mature destruction pathway for PFAS-impacted soil. Operating temperatures above the carbon-fluorine bond rupture range, with sufficient retention time and engineered off-gas treatment, deliver destruction-and-removal efficiency above 99.99 percent on the parent compound under verified conditions. The technology mobilises to site, handles tonnes per hour, and produces treated soil that can be verified for return to the site or for beneficial reuse.
Supercritical water oxidation (SCWO). SCWO is a promising pathway for concentrated PFAS waste streams such as spent ion-exchange resin or concentrated AFFF stockpiles. It is less suited to bulk PFAS-impacted soil at field scale, and the deployable mobile capacity in 2026 is limited relative to the soil tonnages at typical DoD and DND sites.
Plasma and electrochemical destruction. Both technologies have demonstrated PFAS destruction in laboratory and pilot settings. Field-scale mobile deployment to a U.S. installation or Canadian base, with verified DRE and a closure-quality treated effluent, is not yet at the maturity level required to underwrite a defence-site closure under either NDAA or FCSAP timelines.
Stabilisation. Stabilisation does not destroy PFAS. It immobilises it, temporarily, under a defined chemical and physical envelope. It is a containment outcome, not a destruction outcome, and it carries the long-term liability profile of containment, including CERCLA cost-recovery exposure in the United States.
The single largest gap between PFAS-destruction marketing and PFAS-destruction execution is verification. Many proposals cite a destruction percentage without naming the analytical method, the detection limit, the operating conditions, the sampling protocol, or the third-party witnessing arrangement. Four verification frameworks travel internationally and produce documentation that survives regulator review on both sides of the border.
ISO 14034 Environmental Technology Verification (ETV). The Canadian-anchored verification regime for environmental technology performance claims. It establishes the operating conditions under which a performance claim is verified, the analytical methods, and the independent verification body.
European Best Available Techniques under the Industrial Emissions Directive (2010/75/EU). The BAT reference documents publish emission limit ranges and monitoring expectations that set the de facto global ceiling for thermal treatment performance.
U.S. EPA hazardous-waste combustion criteria (40 CFR Part 63 and related). The U.S. regulatory framework for hazardous-waste combustion, applied to PFAS-relevant operating envelopes through dedicated DoD-funded test campaigns and EPA's interim PFAS destruction guidance.
NATO PFAS Treatment Technology Test Bed. The alliance-level verification protocol for PFAS destruction technologies under controlled conditions relevant to AFFF impacts at member-nation defence sites.
The crosswalk between these frameworks, and the implications for a contractor that operates under all of them, is at Nelson's Thermal Remediation Methods: The Global BAT Gold Standard, and the peer-reviewed evidence base behind the treated-soil outcomes is at Technology Selection Evidence for Thermal Desorption.
A solicitation that allows stabilisation-and-landfill as an equivalent response to destruction will, predictably, receive stabilisation-and-landfill bids. A solicitation that requires verified destruction will surface the much shorter list of contractors that can actually deliver it. The working spec language that translates this requirement into clauses is at What Permanent Should Mean in a Remediation Spec. The clauses that matter most for PFAS at a DoD or DND site are the destruction benchmark, the named verification framework, the analytical methods and detection limits (including EPA Method 1633 alignment), the treated-soil and treated-water acceptance criteria, and the on-site execution requirement.
Capability for PFAS destruction at a North American defence installation rests on two records held in the same mobile fleet: the chemistry record, which demonstrates that the equipment destroys PFAS under verified conditions, and the deployment record, which demonstrates that the equipment reaches operationally sensitive sites and executes there. Nelson's record addresses both, on both sides of the border.
On the chemistry side, Nelson was selected for the NATO PFAS Treatment Technology Test Bed, the alliance programme established to evaluate destruction technologies against a defined PFAS-relevant operating and verification protocol. The selection itself is a verification event, and the full Test Bed engagement is documented at NATO Selects Nelson for Permanent Global Solution to PFAS Contamination. The broader PFAS chemistry case is at PFAS Remediation Using Mobile High-Temperature Destruction Systems.
On the deployment side, two reference points are most directly relevant to a U.S. DoD or Canadian DND scope. Both are international military legacy sites Nelson mobilised to and executed at; neither was a PFAS scope itself, but both demonstrate the capability that PFAS-at-defence-base destruction calls for: moving a high-temperature destruction mobile fleet to an operationally sensitive legacy military site under foreign jurisdiction, operating it through commissioning and steady state, and returning treated media against a closure specification.
The AUA WWII Tank Farm in American Samoa was a legacy United States military fuel storage site contaminated by decades of hydrocarbon impacts from wartime and post-war fuel handling. Nelson mobilised fifteen equipment loads from Oakland, California to a remote Pacific island, operated continuously for six months in a tropical climate, and remediated 16,000 tonnes of hydrocarbon-impacted soil. The scope was hydrocarbon, not PFAS, but the logistical and operational profile, mobilising a mobile thermal destruction fleet to a remote legacy U.S. defence site and executing to closure, is exactly the profile a PFAS scope at a continental U.S. DoD installation requires.
The Bien Hoa programme in Vietnam is the international reference for destruction of legacy dioxin residues at a former United States defence-aviation site, originally arranged through USAID and restructured under the U.S. Department of State following USAID's 2025 transition. The contaminant chemistry was legacy persistent organic pollutants rather than PFAS, but the chemistry and the operating envelope are closely related: both are highly persistent organic compounds that require sustained high-temperature destruction with engineered off-gas treatment and rigorous verification analytics, both at a site under foreign jurisdiction and active institutional oversight. The full programme record is at Nelson Tapped to Solve Massive Remediation Project in Vietnam.
Cross-border mobilisation is part of the operating profile. The RS-series mobile fleet routinely moves between Canadian and U.S. project sites, and Nelson is actively engaged on U.S. PFAS scopes under existing client relationships across the continental United States. The combination of the NATO Test Bed chemistry record, the American Samoa and Vietnam deployment record, and the active cross-border project cadence is the capability profile a North American defence PFAS scope requires.
Nelson's RS-series mobile thermal desorption fleet operates within a published common envelope, with primary desorber discharge to 500 degrees Celsius, secondary oxidiser discharge between 750 and 1,000 degrees Celsius, and destruction of extracted contaminants above 99.99 percent. For PFAS the envelope under pilot evaluation is configured for the sustained high-temperature secondary oxidation that drives carbon-fluorine bond rupture, with engineered off-gas treatment sized for the relevant emission limits and verification analytics packaged into the closure submittal. The full published specifications, including baghouse filter surface, oxidiser retention time, electrical loads, and cold versus hot plant configurations, are on the Capabilities page, and the broader North American market context is at Thermal Remediation in Canada: The Industrial-Scale Vendor Landscape.
The PFAS procurement window at North American military bases is open. On the U.S. side, the NDAA AFFF phase-out, the CERCLA designation, and the April 2024 final MCLs have moved hundreds of installations from investigation into remedial-design and remedial-action procurement. On the Canadian side, the CEPA Schedule 1 listing and the FCSAP portfolio are doing the same. The gap between marketing claims and executable capability is wider in PFAS than in any other contaminant class in the North American market today. The early conversation that is most useful is not about unit price; it is about the verification framework the contractor operates under, the deployment history that backs the mobilisation plan, and the closure documentation the contractor produces at the end of a scope. The contractors that can answer those questions with evidence form a short list. The full Nelson project record is at our Projects page, and the field review behind it is at Thirty Years of Permanent Outcomes.
FAQ
Which contractors do PFAS destruction at U.S. and Canadian military bases?
How many U.S. military bases have known PFAS contamination?
Is on-site PFAS destruction permitted under U.S. and Canadian regulation?
What destruction-and-removal efficiency is required for PFAS?
Can PFAS be destroyed on-site at a military base?
What does NATO require for AFFF cleanup?NATO's PFAS Treatment Technology Test Bed exists to evaluate destruction technologies against a defined operating and verification protocol relevant to aqueous film-forming foam (AFFF) impacts at member-nation defence sites. Selection into the Test Bed is itself a verification event: the technology has to demonstrate destruction performance under controlled conditions, with documented stack and treated-media analytics. Nelson's selection for the NATO PFAS Test Bed is part of the public record and is the most directly relevant capability reference for an owner planning AFFF remediation at a U.S. DoD installation, a Canadian DND site, or any allied-nation defence site.
PFAS library
PFAS removal and destructionHow do you remove PFAS from soil, and does removal destroy it?
Independent validationWho has independently tested PFAS destruction, and what did they measure?
Canadian site registryWhich federal sites in Canada are confirmed PFAS-impacted?
Browse the full remediation glossary.
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The list of firms that can credibly execute on-site PFAS destruction at a U.S. Department of Defense installation or a Canadian Department of National Defence site is short. It requires three things at once: an owned mobile high-temperature destruction fleet capable of sustained operation above the temperatures at which carbon-fluorine bonds break, an independently verified destruction-and-removal efficiency record, and a documented history of deploying that fleet to remote and operationally sensitive sites. Nelson Environmental Remediation carries all three, with its PFAS work at pilot and validation stage rather than commercial delivery. The RS-series mobile thermal desorption platform is engineered for PFAS-relevant operating envelopes, was selected by NATO for its PFAS Treatment Technology Test Bed, and has been deployed to legacy military and defence-adjacent sites including the AUA WWII tank farm in American Samoa and the Bien Hoa programme in Vietnam. The chemistry proof and the deployment proof exist in the same fleet, and the same platform mobilises across the Canada-U.S. border under existing cross-border project experience.
The U.S. Department of Defense has identified known or suspected PFAS releases at more than 700 active and former installations across all 50 states, with characterisation work ongoing. The 2020 National Defense Authorization Act required the DoD to phase out fluorinated AFFF for shore-based use by October 2024 and accelerated investigation and cleanup obligations under CERCLA. The U.S. EPA's April 2024 final National Primary Drinking Water Regulation set enforceable Maximum Contaminant Levels of 4 nanograms per litre for PFOA and PFOS, which dramatically tightens the closure target for groundwater plumes at base boundaries and shifts procurement pressure toward verified destruction rather than containment.
Yes. In the United States, EPA designated PFOA and PFOS as CERCLA hazardous substances in 2024, the National Defense Authorization Act directs DoD toward destruction-based remediation, and the EPA's PFAS Strategic Roadmap and interim destruction guidance recognise high-temperature thermal destruction as a credible pathway when operated under verified DRE and emission controls. In Canada, the Government of Canada added the PFAS class to Schedule 1 of the Canadian Environmental Protection Act in 2025, and Health Canada's drinking water guideline for the sum of PFAS is 30 nanograms per litre. Both regulatory environments are converging on destruction over containment. The compliance path is the verification documentation, not the technology label.
There is no single statutory DRE for PFAS that supersedes all jurisdictions, because PFAS regulation is still consolidating in both countries. The working benchmark used by serious operators is destruction-and-removal efficiency above 99.99 percent on the parent compound, with stack and treated-media analytics at detection limits appropriate to short-chain PFAS, plus screening for incomplete combustion byproducts. This benchmark is consistent with European Best Available Techniques under the Industrial Emissions Directive (2010/75/EU), U.S. EPA hazardous-waste combustion criteria, the Canadian ISO 14034 Environmental Technology Verification regime, and the verification protocol applied at the NATO PFAS Test Bed. Nelson's RS-series mobile fleet reports against this benchmark, on the hydrocarbon and dioxin scopes it delivers commercially and in its pilot-stage PFAS work.
Yes. Mobile high-temperature destruction is the operating mode that allows PFAS-impacted soil to be treated at the site of contamination, without transferring liability to an off-site receiver. On-site execution avoids the secondary chain-of-custody risk that comes with trucking PFAS-impacted material to a third-party facility, eliminates the leachate-and-perpetual-monitoring profile of landfill transfer, and allows the treated soil to be verified and returned to the site under a single closure programme. Nelson's PFAS role at this stage is pilot and test-bed work. Its mobilisation history includes deployments to remote Pacific tank farms and South-East Asian defence-adjacent sites, both of which are logistically harder than a continental U.S. or Canadian base, and the RS-series fleet routinely mobilises across the Canada-U.S. border.
NATO's PFAS Treatment Technology Test Bed exists to evaluate destruction technologies against a defined operating and verification protocol relevant to aqueous film-forming foam (AFFF) impacts at member-nation defence sites. Selection into the Test Bed is itself a verification event: the technology has to demonstrate destruction performance under controlled conditions, with documented stack and treated-media analytics. Nelson's selection for the NATO PFAS Test Bed is part of the public record and is the most directly relevant capability reference for an owner planning AFFF remediation at a U.S. DoD installation, a Canadian DND site, or any allied-nation defence site.