LANDFILLS AND PFAS: WHAT DOES THE FUTURE HOLD?
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The U.S. EPA and states across the country are increasingly focusing
on landfills as a source of PFAS contamination.
PFAS IN LANDFILLS: A COMMON PROBLEM
In 2021, the U.S. EPA ran a small study that found PFAS in the leachate of 95% of landfills sampled. Since then, the Minnesota Pollution Control Agency (MPCA) conducted a study of closed landfills, 98% of which were found to be contaminated with PFAS. Given the widespread use of PFAS in commercial and industrial products, it’s no surprise that the presence of PFAS at high concentrations in landfills is common.
PFAS REGULATIONS IMPACTING LANDFILLS
Historically, rulemaking has primarily targeted PFAS in drinking water and wastewater discharge. However, over the last several years, there has been an increased focus on rulemaking targeting PFAS in landfills. PFAS sampling at landfills has been concentrated on leachate and groundwater.
ELGs are regulations established by the U.S. EPA, limiting the level of pollutants businesses are allowed to discharge into surface water and to Publicly Owned Treatment Works (POTWs). Based on research into PFAS in landfill leachate, the EPA determined that establishing ELGs for landfills was warranted. This plan was first announced in ELG Plan 15 and confirmed in Preliminary Plan 16.
Once limits for PFAS in wastewater discharge are set through the Effluent Guidelines Program, they are implemented in NPDES permitting. Most states are authorized by the EPA to administer their own NPDES permitting program. These state permitting agencies will be required to follow EPA-defined limits or establish stricter limits.
With PFOA and PFOS designated hazardous substances under CERCLA, landfills are under increased scrutiny. Both active and decommissioned landfills have been designated Superfund sites.
RCRA focuses on the ongoing management of hazardous waste at currently operating facilities, including the correct treatment, storage, and disposal of hazardous waste to prevent environmental contamination. In February 2024, the EPA proposed designating nine PFAS as hazardous constituents under RCRA: PFOA, PFOS, PFBS, HFPO-DA (GenX), PFNA, PFHxS, PFDA, PFHxA, and PFBA. If this proposal is finalized, it is likely to have a significant impact on solid waste landfills, including those handling domestic solid waste.
The U.S. EPA’s TRI database tracks toxic chemical releases from industrial facilities into the environment. Publicly and privately owned municipal solid waste landfills are not currently required to report PFAS releases under TRI. However, as PFAS regulations evolve, particularly under CERCLA and RCRA, reporting requirements may change.
Once ELGs are set for PFAS in landfill discharge, states will be required to include PFAS in NPDES permitting. Some states are already doing so. In addition, some municipal landfills require biosolids to be tested for PFAS before accepting them for disposal. As PFAS regulations governing landfills get stricter, some may stop accepting biosolids altogether.
WHICH MATRICES SHOULD BE TESTED?
Leachate is a common matrix analyzed for PFAS in the landfill industry. In landfills with an intact leachate collection system, this leachate is typically sent to Publicly Owned Treatment Works (POTWs) for processing. Since traditional wastewater treatment processes do not remove PFAS, this can result in higher levels of PFAS in treated water being released into the environment.
Solid waste facilities may be required to sample their groundwater monitoring wells and downstream surface water bodies in accordance with their permits.
Some states require biosolids, a by-product of the wastewater treatment process, to be tested for PFAS before they can be accepted for disposal. The wastewater treatment facility is usually the entity responsible for this testing.
PACE® PFAS TREATABILITY STUDIES
Pace® PFAS Treatability Studies help clients evaluate the effectiveness of technologies and strategies for PFAS removal, remediation, and destruction. As PFAS regulations move forward, some landfills are already running pilot studies on their leachate to determine which technologies are most effective in PFAS removal and/or destruction at their facilities.
PFAS TEST METHODS FOR LANDFILLS
There are several methods for analyzing PFAS in landfill leachate, groundwater, and biosolids. PFAS rules and regulations often dictate the method used. However, when compliance reporting isn’t required, additional options can offer distinct advantages.
EPA 1633 quantifies more than 40 compounds across a wide range of solid and aqueous matrices, including landfill leachate, wastewater, surface water, groundwater, biosolids, and more. This method will be adopted into SW-846 for the RCRA program and is expected to be promulgated in 40 CFR Part 136. EPA 1633 is often specified for NPDES permitting.
ASTM D8421 and D8535 are PFAS methods developed by the American Society for Testing and Materials (ASTM) to provide a quick, easy, and robust method for PFAS analyses in aqueous and solid matrices, respectively. Technically similar to EPA 8327, Pace® can cite either EPA 8327 or ASTM D8421/D8535. Turnaround times (TAT) for ASTM D8421/ASTM D8535/EPA 8327 are faster than more procedurally challenging methods, such as EPA 1633. In addition, ASTM D8421/EPA 8327 only requires a minimum sample volume of 5 mL to be collected, and with optimized procedural requirements, results can also be delivered at a lower price point. We have incorporated isotope dilution into this method which allows for more accurate quantitation in complex matrices such as leachate.
EPA 1621 measures adsorbable organic fluorine (AOF) in non-potable water, including leachate, which often contains PFAS compounds not detectable by targeted methods such as EPA 1633. EPA 1621 is intended as a screening tool. This method is also a commonly used tool to measure organic fluorine in destruction technology studies.
PFAS precursors are a class of PFAS compounds that can degrade to terminal PFAS compounds under certain environmental conditions, including traditional wastewater treatment processes. TOP Assay oxidizes PFAS precursors, turning them into PFAS compounds that can then be measured by currently available methods.
ON-DEMAND WEBINAR: A DEEP DIVE INTO EPA 8327/ASTM D8421
When compliance reporting isn’t required, EPA 8327/ASTM D8421 can provide faster results at a lower price
point than more procedurally complex methods like EPA 1633. In this on-demand webinar, our PFAS experts
take you deeper into the advantages of this method and discuss how and when it can be used.
REASONS TO CHOOSE PACE®
EXPERIENCED
Pace® has been an industry leader in persistent organic pollutant testing for over three decades.
CERTIFIED
We’re certified/accredited by NELAC, ISO, DOD, DOE, and in every state with a PFAS lab certification program.
RELIABLE
For emergencies, our Rapid Response Team can provide defensible results in as little as 24 hours.
COMMITTED
We are committed to helping our customers advance their important work through building strong relationships, delivering upon expectations, and providing exceptional customer service.
ADVANCED
We can test for PFAS in both solid and aqueous matrices, including potable and non-potable waters, soils, and biota.
INNOVATIVE
We’re on the leading edge of science, working with EPA, DOD, ASTM, and others to develop new methods for analyzing PFAS.
