Preparing for PFAS

The impact of per- and polyfluoroalkyl substances (PFAS) on my compliance monitoring program became apparent about a year ago. PFAS—a group of approximately 3,500 manmade chemical compounds that can be found in landfill leachate, wastewater, sludge disposed in landfills and wastewater treatment plant biosolids, among other applications—have recently caught the attention of regulators intent on improving landfill monitoring.

As someone responsible for environmental compliance and monitoring of both an operational municipal solid waste (MSW) landfill and a newly closed landfill, I felt uneasy over new sampling requirements, as I didn’t know the impact these substances would have on my annual monitoring costs. Due to the contaminants’ ubiquitous presence (which presents a cross-contamination issue), PFAS are impacting post-closure budgets by increasing the costs for revised Sampling and Analysis Plans (SAP), as well as increasing costs for shipping containers, handling and reporting.

The waste management industry is uncertain about how to appropriately establish risk-based criteria for evaluating these contaminants. I contend that the first step is understanding where these substances are found in the products we throw away and how they are processed in our solid waste management systems. In addition, we need to ask ourselves how we will limit the level of these substances found in products that were made in other countries and find their way into domestic landfills.

Part of the struggle to appropriately legislate the issue is how new the subject of PFAS is to most in the industry. I recently attended a conference where PFAS were the topic of several sessions. Because much of the research on these substances is so recent, there was not a study referenced older than 2017. The relative lack of knowledge on this subject is limiting the industry’s ability to develop a consistent approach in tackling the problem.

In states such as North Carolina, where GenX (a short-chain version of PFAS) is manufactured, these compounds have been shown to impact air, surface water and groundwater alike. For this reason, a proactive multiagency response has been required to identify these sources of contamination and safeguard the public. In response to this (and other PFAS concerns in the state), North Carolina has decided to start sampling leachate at MSW landfills for these substances. They will be analyzing for perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid (PFOA) and GenX (where warranted) and conducting a full scan of PFAS compounds on a site-specific basis.

The federal government currently has no requirement for sampling PFAS, nor an acceptable exposure level. Some states, however, are preemptively moving forward with PFAS standards and monitoring practices. About two dozen states currently have, or are considering, limits for these substances. This has resulted in varying levels of monitoring and enforcement oversight.

One simply needs to search “PFAS lawsuits” online to see how this has quickly become a hot-button issue, not unlike when the far-reaching use of asbestos caught the industry’s attention in years past. In October 2018, for example, an Ohio firefighter filed a class-action lawsuit against PFAS manufacturers in U.S. District Court. In mid-May of this year, the state of New Jersey filed a similar lawsuit.

While much is still unknown regarding PFAS’ impact on the environment, the big questions around this contamination currently are, “How bad is it, and how bad will it get?” Without a crystal ball, all we can do now is anticipate monitoring requirements, stay tuned for new legislation, research new monitoring and analytical methods and make good judgement calls in the interim. Although no one can predict the future, landfill and other waste management facility operators might consider bolstering their monitoring and compliance budgets for the long term now to be ready for what comes next.