Proposed EPA regulations to address PFAS in landfills

Landfill leachate metering and a sampling manhole can be used as a sampling point for testing PFAS levels.
A municipal solid waste landfill (MSWLF) is a dedicated land area or excavated site that receives nonhazardous solid waste from households and industries. An MSWLF may also receive nonhazardous sludge and conditionally exempt small quantity generator waste.
These landfills safely isolate waste from the environment with clay and geotextile liners to prevent groundwater contamination through leachate collection. Leachate is formed when rainwater filters through the waste in a landfill. As the liquid comes in contact with the buried wastes, it leaches or draws out chemicals.
Under the Resource Conservation and Recovery Act (RCRA) regulations, landfill operators should collect the leachate. Landfill operators collect and discharge wastewater to surface water or publicly owned treatment works (POTWs). As per- and polyfluorinated alkyl substance (PFAS) compounds are widely present in manufacturing, commercial and consumer products, municipal landfills have received PFAS-laden waste for decades. This, in turn, contaminates the leachate with effluents that end up in nearby surface water and drinking water supplies.
The U.S. Environmental Protection Agency (U.S. EPA) announced plans for new effluent limitation guidelines and pretreatment standards for leachate because of PFAS in landfills. It is important to stay updated on these effluent limits and leachate treatment guidelines to avoid penalties and protect the environment and groundwater from PFAS.

How the EPA aims to address PFAS in landfills

The EPA has not approved a standardized sampling method for landfill leachate, making it hard to replicate studies for risk analysis. Also, studies have shown that landfill leachates may contain Perfluoroalkyl acid (PFAA) precursors that are converted into PFAAs. Conventional treatment processes may risk converting these precursors into more toxic and persistent PFAAs, thereby increasing the concentration of PFAS in treated leachate than in its raw state.
Landfills do not generate PFAS on their own but receive PFAS-containing waste that compromises the health and safety of an estimated 13.2 million people who live within a mile of a landfill in the U.S. The EPA considers PFAS in landfill leachate as a 'challenging matrix,' highlighting the ongoing research and proposed regulations on sampling, effluent limits and remediation technologies. The following table highlights key EPA actions to address PFAS in landfills.


EPA actions to address PFAS in landfills



Analyze and treat emerging contaminants (PFAS) in solid waste, landfills, wastewater/ leachates, soil and groundwater. 

This was one of the earliest actions in 2018 to address PFAS in landfills. The EPA invited research applications on methods to analyze and treat PFAS in solid waste and landfills.   

Study 200 landfills.

In September 2021, the EPA conducted a study of 200 landfills and found the presence of PFAS in leachate at 95% of the locations. Sixty-three PFAS were identified at the surveyed sites.  

Launch Plan 15.

The final Effluent Limitations Guidelines (ELGs) Plan 15 was released in January 2023. It aims to revise ELGs and pretreatment standards to reduce PFAS in leachate discharges from landfills. 

Plan 15 also includes expanding the ongoing study of PFAS discharges from textile manufacturers and a new study of POTW influents.   

Additionally, the EPA will conduct a detailed study of the concentrated animal feeding operations category.   

Plan 15 is considered a potentially significant development to address PFAS in landfills. It is unclear when the proposed rules will take effect or how they might affect regular landfill operations. Municipal leaders await further EPA actions on PFAS in wastewater and certain drinking water standards that could affect operations.
Partnering with a team of environmental professionals can help community leaders take the required actions to address PFAS in landfills.

Partner with environmental professionals to address PFAS in your community

At Fehr Graham, we are an experienced team of professionals committed to helping municipal leaders protect residents and the environment from the adverse effects of PFAS compounds. Whether you are updating your community on the latest PFAS regulations or securing funds for system upgrades, we are here to help you navigate every stage of the process. With our end-to-end assistance in water and wastewater engineering, we ensure projects comply with all proposed standards for PFAS chemicals in soil and water.

To learn more about how Fehr Graham can help limit PFAS in landfills in your community, contact us or call 608.329.6400.