PFAS: How can this class of chemicals impact management of Ontario’s Landfills?
By Douglas Smith, GHD and David Barton, GHD – January 29, 2020
Recently, there has been growing awareness in the Waste Management Industry around a group of widely used chemicals known as per- and polyfluoroalkyl substances (PFAS). These chemicals are extremely stable, and move with water in the natural environment. This class of chemicals is present in many products that people use, and it is becoming clear that they will affect our waste streams. What do you need to know about the quickly evolving regulations? What do you need to know to stay in front of this issue? We look at what the science says, how regulators are responding, and how that may affect the Waste Management Industry.
What are PFAS?
PFAS is an umbrella term for more than 5,000 compounds, including perfluoroctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), which are the two most talked about PFAS. PFAS compounds are in fire-fighting foams, non-stick products (e.g., cookware), water and stain resistant fabrics (e.g. waterproof clothing, carpets), used in plating operations, in packaging materials, and in many other commercial and industrial processes. Unfortunately, some of the properties that make PFAS so useful
are what make them so difficult to address when in the environment. The chemical bond is exceptionally strong, making them difficult to treat, and they are potentially toxic to human health and the environment.
How is this impacting the Waste Management Industry?
As waste-containing PFAS is disposed of in landfills, and these waste materials release PFAS through to the leachate, landfills may be considered secondary sources. Regulators are increasingly taking an interest in PFAS at landfills across the US, and recently, the Ontario Ministry of Conservation and Parks (MECP) is showing a greater interest in these chemicals. While most of the attention by regulators and media so far has focused on PFAS industrial users and manufacturers, the waste management industry also needs to be prepared to manage risks from the various waste streams. Waste management facilities that have received PFAS containing material, in particular landfills, may need to consider PFAS when:
- Making decisions around waste acceptance
- Evaluating leachate management options, particularly discharges to waste water treatment facilities that may in the future have their own discharge limits
- Budgeting for future groundwater monitoring programs
- Completing facility designs
- Developing closure plans and long-term maintenance plans
What is the Waste Management Industry Doing?
While not a primary source of PFAS to the environment, the Waste Management industry in the US has taken a role in efforts to quantify PFAS at facilities in light of the advancing science.
There have been many efforts to quantify PFAS at Waste Management facilities, including by the Michigan Waste and Recycling Association (MWRA), who in March 2019 summarized the results of their statewide landfill study. The study included leachate tested from 32 active municipal solid waste landfills within the state of Michigan. Some of the main conclusions from the study were:
- PFOA and PFOS were detected in all of the leachate samples taken in the study
- Concentration ranges were similar to previous leachate studies conducted elsewhere in the US
- Leachate sampled from landfills that participated in this study had PFOA concentrations ranging from 240 to 3,200 parts per trillion (ppt) and PFOS ranging from 100 to 710 ppt.
For reference purposes, Health Canada has established guideline values of 200 ppt and 600 ppt for PFOA and PFOS, respectively (among several other PFAS chemicals) and the United States Environmental Protection Agency has established a more stringent lifetime health advisory of 70 ppt for PFOA and PFOS. While the MECP has taken an increasing interest in PFAS concentrations at Ontario facilities, there presently are no standards in Ontario.
In a nutshell, what does all of this mean?
Awareness of PFAS is growing, and regulators across North America (including Ontario) are increasingly taking interest. As PFAS have been common ingredients in everyday commercial products that ultimately are disposed of at landfills, PFAS is likely present in the leachate of many landfills across Ontario. As such, the Waste Management Industry needs to prepare for addressing the associated liabilities with respect to PFAS. Generally, in the US, the Waste Management Industry is actively engaged in efforts to quantify PFAS at waste management facilities and are in discussions on proposed regulations in future regulations. Waste management facilities in Ontario should make similar preparations and try to educate themselves on the issue.