Limiting Liability

Comparing Potential Disposal Methods for PFAS-Contaminated Waste

Disposal of hazardous and non-hazardous waste at redevelopment or remediation sites is routine … until PFAS gets involved. The presence of PFAS in waste can occur for many reasons, ranging from decontamination fluid from a groundwater sampling event to soil that was excavated after an AFFF release. Regardless of the level of PFAS in your waste, its presence must be considered prior to disposal.

Key Takeaways

• PFAS significantly increases regulatory scrutiny and long-term liability in waste disposal
• Landfills are tightening acceptance criteria, with future RCRA rules likely making PFAS a cradle-to-grave risk
• Emerging technologies show promise, but disposal decisions still require balancing cost, risk, and effectiveness

WHAT ARE THE OPTIONS FOR DISPOSAL OF PFAS-CONTAMINATED WASTE?

There are multiple approaches to disposing of PFAS-contaminated waste, and selecting the appropriate method is critical. While choosing a pathway can feel overwhelming, Langan’s PFAS team works with clients to navigate a project’s specific needs, evaluate available disposal options, and identify low-risk and cost-effective solutions.

Currently, landfilling untreated PFAS-contaminated waste is one of the most common disposal methods due to its availability and relatively low cost, but that is changing. Facilities are under pressure to stop accepting PFAS-contaminated waste due to continually evolving regulations and concerns associated with landfill leachates. Incoming Resource Conservation and Recovery Act (RCRA) “cradle-to-grave” regulations for PFAS—specifically, PFAS becoming a RCRA hazardous substance—will push landfills to begin including PFAS in contaminant monitoring programs. A detection could potentially trigger a cleanup, reintroducing liability to both the landfill and the original generator.

HOW ARE LANDFILLS RESPONDING TO EVOLVING PFAS REGULATIONS?

With continued uncertainty surrounding PFAS regulations, some disposal facilities have become increasingly selective about the types of PFAS waste they accept, largely driven by concerns regarding future potential liability. According to U.S. Department of War’s (DoW) February 2026 guidance “Detailed Analysis of Options for the Destruction and Disposal of Covered Materials Containing Per- and Polyfluoroalkyl Substances,” the U.S. Environmental Protection Agency and the DoW identify specific landfill types as preferred waste management options for PFAS-containing materials, due to their ability to minimize PFAS emissions in the environment and reduce potential human health exposures. The recommendations are limited to solid waste landfills with composite liners, leachate collection and treatment systems, and applicable environmental permits. Additionally, DoW guidance prohibits the disposal of firefighting foam concentrates and other liquid PFAS-containing materials in these landfills, directing such wastes to alternative disposal methods.

Another option for disposal of PFAS-containing materials is a permitted hazardous waste landfill (also known as a RCRA Subtitle C landfill), which is a landfill recognized as having a lower potential for environmental releases. RCRA landfills have additional processes and protections, including containerizing or segregating wastes, incorporating double liner systems with leachate collection and leak detection systems, and requiring extensive recordkeeping. Waste origin must be considered; for example, biologically active materials are generally not accepted. There may also be pre-treatment requirements, such as the solidification of PFAS-containing liquids prior to disposal.

Selecting an appropriate disposal option for PFAS–containing waste can be complex. Langan’s team of PFAS experts is well-versed in the intricacies of this selection process and can provide guidance to support informed decisions, limit potential future liabilities, and help manage emerging environmental conditions.

PFAS Disposal FAQs

Who is responsible for PFAS-contaminated waste disposal liability?

Liability for PFAS-contaminated waste can extend to multiple parties, including the original generator, transporter, and disposal facility. With potential RCRA designation, PFAS may be regulated under a “cradle-to-grave” framework, meaning responsibility can persist even after disposal.

Can PFAS-contaminated waste be disposed of in standard landfills?

In some cases, low-level PFAS waste may still be accepted at certain landfills, but acceptance criteria are becoming more restrictive. Many facilities are tightening requirements or rejecting PFAS-containing materials altogether due to regulatory pressure and long-term liability concerns.

What is the safest way to dispose of PFAS-contaminated waste?

Engineered hazardous waste landfills (such as Subtitle C facilities) are often considered the lowest-risk option. These facilities are designed to contain contaminants and prevent environmental release through monitoring and control systems.

Why is PFAS waste disposal becoming more expensive?

Costs are increasing due to stricter landfill acceptance criteria, evolving regulations, limited disposal options, and the need for specialized treatment or destruction technologies. As PFAS regulations continue to develop, compliance and long-term liability considerations are also driving up costs.

Grayson Basalyga is a Project Scientist in Langan’s Philadelphia office, specializing in environmental investigation and remediation. His expertise includes site and remedial investigations; fieldwork in soil, groundwater, and indoor air media; utilization of environmental tools and technology for site characterization; and report writing for client deliverables.