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Evaporation, foam fractionation and hauling may buy time, but they will not buy long-term compliance. Now more than ever, future-ready landfill operators must rethink PFAS and beyond.
By Greg Ackerson

Thinking of PFAS, aka per- and polyfluoroalkyl substances, as the problem can be tempting. But if you operate a landfill, PFAS are just the tip of the iceberg. While operators scramble to comply with emerging PFAS regulations, a more fundamental question looms: What happens when the next wave of contaminant regulations arrives?

Since today鈥檚 stopgap leachate management methods will not scale into tomorrow鈥檚 compliance landscape, the answer lies not in chasing each regulatory shift with temporary fixes, but in building comprehensive, onsite treatment systems that can adapt to whatever standards emerge next.

As regulatory scrutiny intensifies and wastewater treatment plants begin rejecting PFAS-laden leachate, forward-thinking landfill operators must act before the inevitable regulatory crunch makes compliance exponentially more expensive and complex.

The Hidden Flaws in Traditional Treatment
Roughly 99 percent of U.S. landfill leachate is hauled or piped directly to wastewater treatment plants. From there, the leachate is treated using infrastructure rooted in 19th-century science: a biological process driven by microorganisms鈥攐r 鈥渂ugs鈥濃攖hat break down organic material. The wastewater treatment process, while effective for nitrates, barely touches other threats. PFAS, heavy metals, pharmaceuticals and carcinogens are not treated but diluted. And then eventually discharged into creeks, rivers and watersheds.

The traditional approach worked when regulations were minimal and treatment plants welcomed the revenue. But that era is rapidly ending. Wastewater treatment plants excel at processing organic waste through biological processes, but they are woefully inadequate for today鈥檚 complex chemical cocktail. PFAS, heavy metals, arsenic, pharmaceuticals and industrial chemicals pass through largely unchanged, merely diluted before discharge.

The bacterial systems that form the backbone of municipal treatment are particularly vulnerable to leachate鈥檚 toxic load. Dark, concentrated leachate can kill the beneficial bacteria essential to treatment processes, disrupting entire facility operations. When chlorine, UV disinfection and other treatments cannot penetrate darkened water streams, compliance becomes impossible.

As discharge standards have tightened鈥攆irst nitrogen, then phosphorus and chlorides, now PFAS鈥攖reatment plants steadily view leachate as more of a liability than a revenue opportunity. The result? Higher fees, stricter acceptance criteria and outright rejection of leachate shipments.

 

Before and after WARP. Landfill leachate before treatment (left),聽and聽the clean water after (right).
Images courtesy of Apex Water Solutions, LLC.

Stopgap Solutions Create Longer-Term Problems
Faced with growing treatment plant resistance, some operators have turned to emerging technologies that promise PFAS reduction. Foam fractionation, for example, exploits PFAS molecules鈥 soap-like properties: dual hydrophobic and hydrophilic characteristics make them cling to air bubbles. The foam fractionation process can remove 70 to 99 percent of certain PFAS compounds, depending on their molecular structure.

While impressive for PFAS reduction, foam fractionation exemplifies the shortsightedness of single-contaminant solutions. Operators still face hundreds of other contaminants of concern鈥攃arcinogens, heavy metals, arsenic, boron, ammonia, etc. Consequently, expensive foam fractionation systems become an additional operational cost layered onto existing trucking and treatment expenses, without eliminating the fundamental problem.

Granulated activated carbon filtration faces similar limitations. Yes, carbon binds many contaminants, but not all of them. And spent carbon typically returns to the landfill, consuming valuable airspace while creating a false sense of treatment.

Evaporation systems reduce leachate volume but concentrate remaining contaminants. Even advanced evaporation-condensation systems that claim 80 to 90 percent PFAS removal still leave operators managing residual contaminated leachate through traditional hauling and treatment.

Unfortunately, these temporary approaches share a fatal flaw: They are designed to meet today鈥檚 PFAS regulations while ignoring the regulatory trajectory. Worse yet, millions of gallons of contaminated leachate remain untouched. The residual leachate still requires hauling and disposal, meaning operators must add treatment costs on top of trucking fees, without removing all contaminants, achieving regulatory certainty or even gaining independence from increasingly reluctant wastewater facilities.

The Unsustainable Reality of Leachate Hauling
On paper, hauling sounds straightforward. But it is a fragile, unsustainable model economically, operationally and environmentally. Consider this: Even a small landfill can generate 2 million gallons of leachate annually. A midsize site鈥攗pward of 10 million gallons. Larger operations report more than 25 million gallons per year. And all of it must go somewhere.

When wastewater treatment plants stop accepting these volumes鈥攁nd economic and regulatory pressures suggest they will鈥攐perators face an existential crisis. Trucking costs continue climbing due to driver shortages, fuel prices and increased insurance premiums for hazardous material transport. In winter, icy roads make hauling even riskier. During spring runoff, open cells can overwhelm temporary storage, forcing 24/7 hauling to keep pace with rising volumes. Meanwhile, treatment plants charge premium rates for increasingly unwelcome leachate while accepting smaller volumes.

The mathematics of hauling has become unsustainable. Operators find themselves trapped between impossible alternatives: violate regulations by allowing leachate accumulation or violate economics by running continuous trucking operations.

The Regulatory Squeeze Tightens
The EPA鈥檚 PFAS drinking water standards鈥攎easured in parts per trillion鈥攊llustrate the direction of regulatory evolution. Detection technology has advanced far beyond treatment capabilities, creating an enforcement environment where noncompliance becomes inevitable under traditional approaches.

PFAS represents just the beginning of this regulatory tightening. Draft standards for biosolids threaten to eliminate one of wastewater treatment鈥檚 primary disposal methods. When treatment plants can no longer spread their sludge on agricultural fields due to PFAS contamination, they will face disposal crises of their own.

Complicating matters, states often impose stricter standards than federal minimums, creating a patchwork of escalating requirements that vary nationwide. Even if federal policy shifts slow EPA initiatives, state-level regulations continue tightening. Eleven states have implemented enforceable standards like Maximum Contaminant Levels (MCLs) for certain PFAS chemicals in drinking water that go beyond the federal proposals.

The mathematical reality is stark: As detection limits drop and regulated contaminant lists expand, traditional dilute-and-discharge approaches become statistically impossible to maintain. Every new regulation increases the probability of violations, creating cascading compliance failures across interconnected systems. Industry analysts predict that comprehensive leachate treatment requirements will become mandatory within five to 10 years as wastewater treatment plants exit the leachate business entirely.

Landfill Operators Must Embrace Onsite Solutions
A small but growing number of operators recognize that comprehensive onsite treatment represents the only sustainable path forward. These early adopters understand that regulatory trends point toward one inevitable conclusion: containment and treatment of all contaminants, not just today鈥檚 priority chemicals.

Reverse osmosis technology offers the closest approach to universal contaminant removal available today. Operating like a microscopic colander, reverse osmosis membranes remove not only PFAS but hundreds of other contaminants of concern, allowing very little other than pure water to pass through. Everything larger than water molecules remains behind, creating near-distilled-water-quality effluent that meets national drinking water standards and a concentrated residual stream that can be safely sequestered back into the landfill. This is not theory. It is a proven practice (see Case Study: Kandiyohi County Landfill sidebar).

 

 

Turning Waste into Wealth through Strategic Sequestration
The counterintuitive reality of modern landfill design is that these facilities represent some of the most sophisticated containment systems ever constructed. Multiple layers of clay, synthetic liners and collection systems create barriers designed to last. Yet traditional leachate management undermines this investment by diluting and discharging the very contaminants these systems were designed to contain.

Municipal solid waste landfills contain 40 to 65 percent organic material鈥攂anana peels, coffee grounds, food scraps, paper products鈥攖hat creates an enormous carbon filtration matrix. Organic landfill content provides a tremendous binding capacity for returned contaminants. Rather than recirculating through the system, contaminants bind within the landfill鈥檚 carbon, achieving permanent sequestration.

Sequestration transforms landfills from temporary waste storage into permanent contaminant repositories. Instead of allowing harmful chemicals to enter waterways and biosolids, comprehensive leachate treatment with onsite sequestration prevents these materials from entering food and water supplies.

The Risk of Waiting
Despite all of this, adoption has been slow. Why? Culturally, landfill operations are conservative. Most managers are focused on today鈥檚 volumes, budgets and airspace, not what the EPA might do next year. But change is coming fast. It takes up to nine months to build an onsite treatment system. If EPA mandates PFAS limits for biosolids or wastewater discharge鈥攁s expected鈥攚astewater treatment facilities will move quickly to cut off challenging waste streams like leachate.

When that happens, everyone still dependent on hauling will be left with a problem 鈥 and a waitlist. The price of procrastination goes beyond higher treatment costs. It is noncompliance, reputational risk and reactive scrambling under regulatory pressure.

Redefining the Landfill鈥檚 Role
We have long thought of landfills as the end of the line. But when it comes to PFAS and other contaminants, they may also be the best line of defense. By managing leachate onsite and sequestering residuals within the landfill鈥檚 organic matrix, we keep dangerous compounds out of our water, food and environment. And it is far more logical than spending billions to remove PFAS from drinking water while continuing to dump it into rivers.

You cannot stop leachate from forming. But you can stop treating it like someone else鈥檚 problem. Onsite leachate treatment systems offer the rare combination of better compliance, lower risk and real cost control. In an industry where regulations tighten and margins shrink, the future is not dilution and discharge. The future is treatment and sequestration. And it starts onsite. | WA

Greg Ackerson is the CEO of Apex Water Solutions, LLC, which produces the WARP (Wastewater Alternative Remediation Process) System, the only complete onsite treatment that treats leachate to national drinking water standards, removing PFAS and other contaminants of concern to nondetectable levels without any chemical or biological pretreatment, giving landfill operators control, compliance and a truly sustainable leachate treatment solution. Contact Greg Ackerson at [email protected].. Contact Greg Ackerson at [email protected]

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