PFAS in Solid Waste: Regulatory Gaps
PFAS in solid waste—including consumer products, industrial wastes, and AFFF-contaminated materials—create landfill leachate and incineration emissions that spread contamination. Federal waste management regulations have not kept pace with PFAS risks.
Landfill Leachate: An Underregulated Pathway
Landfill leachate contains elevated PFAS concentrations from disposed consumer products. When leachate is sent to publicly owned treatment works (POTWs), PFAS pass through to surface water discharges. EPA is developing POTW effluent guidelines addressing PFAS in leachate.
Incineration and Destruction Standards
Incineration at adequate temperatures (>1,100°C with sufficient residence time) can destroy PFAS compounds. However, incomplete combustion generates PFAS-containing emissions. EPA is developing guidance on incineration conditions sufficient for PFAS destruction.
Hazardous Waste Designation Implications
EPA’s potential RCRA hazardous waste designation of certain PFAS would trigger stringent landfill liner and leachate treatment requirements. Industry groups argue such designation would create prohibitive compliance costs without proportionate environmental benefit.