The U.S. Environmental Protection Agency (EPA) has launched a broad-ranging PFAS Strategic Roadmap aimed at effectively managing Per- and Polyfluoroalkyl Substances (PFAS) in diverse environments, including air, water, soil, and wastewater systems. This roadmap underscores the EPA’s commitment to addressing the challenges posed by PFAS, a group of synthetic chemicals extensively used in various industrial and consumer products for their resistance to heat, water, and oil.
While over 10,000 PFAS variants are known, only a small proportion are currently under regulatory scrutiny, with the number of regulated PFAS varying across countries and regions.
In the United States, the EPA concentrates regulatory and monitoring efforts on a select group of PFAS, primarily due to the scientific complexity of these compounds, analytical limitations, limited toxicity data, and the vast diversity of PFAS chemicals.
This SCS Engineers blog series, Navigating PFAS Compliance, delves into the regulations, management, and monitoring of PFAS at municipal solid waste (MSW) landfills, addressing environmental mediums including air, groundwater, wastewater (i.e., leachate), soil, and waste.
Landfill Regulations and Revisions Anticipated in 2024
Landfills are subject to various regulations, notably under the Resource Conservation and Recovery Act (RCRA) for both hazardous and non-hazardous waste, the Clean Air Act (CAA) for air emissions, and the Clean Water Act (CWA) for water resource protection. The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, also plays a role in addressing contaminated landfill sites, particularly those that pre-date the promulgation of the RCRA Subtitle D program in the early 1990s.
Currently, RCRA does not have specific PFAS regulations for MSW landfills. However, the EPA is developing a rule to classify certain PFAS as “hazardous constituents” under RCRA. We anticipate the proposal in 2024.
Additionally, the EPA has already proposed listing two PFAS constituents – Perfluorooctanoic acid (PFOA) and Perfluorooctanesulfonic acid (PFOS) as hazardous substances under CERCLA, a move that could impact environmental cleanup and liability, particularly for landfills with releases impacting groundwater and adjacent areas. We anticipate the final CERCLA hazardous substances listing in 2024.
The EPA is also revising Effluent Limitation Guidelines to limit PFAS discharges into municipal wastewater treatment facilities. These include amending the Landfills Point Source Category ELGs under Effluent Guidelines Program Plan 15.
While research directly characterizing PFAS in landfill gas is limited, the presence of semi-volatile PFAS in municipal solid waste suggests their occurrence in landfill gas. The EPA is formulating regulations to control PFAS air emissions from multiple sources (e.g., LFG systems), with specific details yet to be fully established.
Federal and State Policies Evolve
The regulatory landscape for PFAS is swiftly evolving, with numerous states setting or updating PFAS standards to address emerging concerns and research findings. States like Alaska, Colorado, Delaware, Florida, Illinois, Indiana, Iowa, Maine, Michigan, Minnesota, Montana, Nevada, North Carolina, Pennsylvania, Rhode Island, Texas, Vermont, and Washington have implemented various PFAS standards.
Managing PFAS in landfills requires a comprehensive approach that includes advanced treatment technologies, compliance with changing regulations, continuous monitoring of the regulatory landscape, and, where necessary, remediation.
This SCS blog series will explore and report PFAS issues across each regulatory category impacting MSW landfills, offering insights into compliance, management, and regulatory aspects. Feel free to contact the authors with questions or comments; we’re here to help.
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Jeff Marshall, PE, is a Vice President of SCS Engineers, Environmental Services Practice Leader for SCS offices in the Mid-Atlantic region, and our National Expert on Emerging Contaminants and Innovative Technologies. His four decades of experience include a diversified background in project engineering and management, emphasizing environmental chemistry, hazardous materials, waste and human health risk issues. Focus areas include environmental permitting, regulatory compliance, and hazardous materials treatment and remediation. He is a licensed professional engineer in Virginia, Maryland, West Virginia, North Carolina, and South Carolina.
David L. Palmerton, Jr., PG, has more than 35 years of experience in environmental consulting in environmental liability assessment, investigation, remediation, due diligence, and construction quality control. His experience includes consulting with large commercial, industrial, and academic entities. He also has extensive experience with the energy industry, specifically oil and gas upstream operations. He has managed strategic and technical environmental consulting issues for Fortune 100 companies throughout the United States. Mr. Palmerton is a professional geologist in several states and a former Certified Hazardous Materials Manager.
