What Evolving PFAS Standards Could Mean for Landfills and Industry

Per- and polyfluoroalkyl substances, or PFAS, continue to sit squarely in the mainstream conversation, and federal and state regulators are making moves to establish standards. In March, the U.S. Environmental Protection Agency proposed the first-ever drinking water standards for six common PFAS. Across the U.S., individual states are implementing or discussing PFAS testing and threshold regulations across several sectors beyond drinking water.

Landfills and industry are some of the leading contributors to PFAS contamination. According to a 2020 study in Michigan, the majority of significant sources were landfills, metal finishers and contaminated sites associated with industries or activities with PFAS usage. So, while national PFAS drinking water standards don't address industrial users now, ambitious standards for discharge practices and standards are being developed by the EPA and some state regulatory agencies. Here's what you need to know.

Current PFAS Regulations, and How They Affect Landfills and Industrial Users

Compared to what other states and countries have done, the EPA’s proposed drinking water standards for PFAS detection are very low at 4 parts per trillion. The standards won't go into effect until the public comment period and review is complete, but when they do, focus will likely start to shift upstream to industrial wastewater discharge permits. The EPA is assessing pretreatment standards that will likely affect the permits that are issued by environmental regulatory agencies to industrial users including landfills or manufacturers, that discharge water that flows into publicly owned treatment works, or POTWs. Permits already have a variety of testing and treatment requirements, and PFAS limits could be added to the list.

Individual states have been implementing industry PFAS regulations for several years. For example, North Carolina recently released a policy that will require two rounds of sampling for landfill leachate, surface water and groundwater as part of the regular monitoring program. The state will review each report, then determine the next steps for potentially mitigating or reducing PFAS. Several states have also set PFAS maximum contaminant levels in drinking water. These standards haven't had a significant effect on industrial discharge permits yet, but they have implored landfills to understand PFAS levels and reduce PFAS from their leachate. And where municipal wastewater treatment facilities are converted to water reuse facilities, which recover valuable resources from wastewater, PFAS are already being limited.

Right now, many landfills and industrial users are taking a wait-and-see approach. Regulations aren't moving at a rapid pace yet, but they are moving toward more scrutiny on solid waste, operations and discharge. Over the next three to four years, we expect significant movement in testing and treatment requirements for these sectors.

Potential Costs and Responsibilities for Landfills and Industrial Users

We'll be watching closely to see how national drinking water standards are enforced. If the EPA’s proposal is adopted as is, states will have to adopt, and oversight could fall to local permitting authorities. Local and regional authorities could then implement standards on wastewater treatment facilities, who might regulate PFAS inputs upstream. The EPA released a financial estimate from their proposal, which came out to about $775 million, but there are some in these sectors who believe the estimate may be low because implications could vary from industry to industry and state to state.

Regardless, as the drinking water standards work their way up to industrial discharge permits, costs could rise significantly. Monitoring and testing for PFAS is expensive, and if landfills and industry are required to add these monitoring parameters to their requirements, they will have to carefully budget for the rise in costs. Onsite pretreatment may be required as well, which adds another layer of cost and consideration.

Methods for testing and mitigation will improve — in cost and effectiveness — as time goes along, but it's hard to predict what the options will look like over the next several years as regulations are implemented. As of now, things look costly.

What Can Landfills and Industrial Users Do Right Now?

Start preparing. If you operate a landfill and/or have an industrial discharge or pretreatment permit, think through the process and cost implications of adding PFAS sampling and analysis into your monitoring program. Sampling and analysis procedures require some careful consideration to eliminate cross-contamination and produce valid results.

Take it a step further and do your own investigation into current PFAS levels. Even if the EPA or state haven't already stepped in to require it, you'll be in the driver’s seat when they do. And it really is a matter of when, not if. Partner or reach out to your water agencies as well, so you can be on top of any changes. 

PFAS Removal and Destruction Methods Are Under Development

There are PFAS removal and destruction solutions in the works at HDR and across the country. We're working on a novel project that will both remove and destroy PFAS for landfill and industrial wastewater streams. This project has primarily been pilot tested for landfills, and early results have been promising. Other applications include drinking water plants and industry, like metal finishing or textile manufacturers, two leading industrial contributors of PFAS.

The goal of the project is to capture the PFAS in less than 1% of the flow being treated and reduce the concentration in treated water to under 1% of the initial PFAS concentration. So far, our approach appears to be much more cost-effective than other available commercial options for landfills.

Landfills are well positioned to be a part of the PFAS solution. They receive PFAS via household garbage and can also accept residue and sludge produced by PFAS removal treatments elsewhere. Some research has indicated that a majority of PFAS remain bound in waste. When mobilized in leachate, these compounds can be removed and returned to the landfill, or subject to a destruction technology, breaking the PFAS cycle. An approach like the one we're developing could play a key role as collaboration between landfills, POTWs and drinking water plays out over the next several years.

Jeff Murray, Landfills Practice Lead
Practice Lead, Landfills
John Schubert | Industrial Process Technology Lead
Industrial Process Technology Lead