Here’s what landfill and wastewater operators need to know
Regulations continue to tighten around PFAS. Down Under, the state of NSW is looking to better understand where these chemicals are presenting, and how they move through the environment.
From 1 October 2026, new NSW EPA requirements will require licensed landfills and sewage treatment plants (STPs) across the state to undertake PFAS monitoring under the Landfill and Sewage Treatment Plant PFAS Monitoring Chemical Control Order 2025. These requirements also comply with Australia’s PFAS National Environmental Management Plan (PFAS NEMP 3.1).
This new monitoring requirement will directly impact Councils, wastewater authorities and landfill operators. We have developed this blog to break down what’s required and to consider what further action is likely once results become available.
Underpinning these new requirements is an understanding that landfills and wastewater systems are passive receivers of PFAS, and that presently these systems can act as pathways for PFAS movement due to the widespread presence of these chemicals in consumer, industrial and commercial waste streams.
What PFAS compounds are to be monitored?
The requirements apply to four specific PFAS compounds:
- PFOA (perfluorooctanoic acid)
- PFOS (perfluorooctane sulfonic acid)
- PFHxS (perfluorohexane sulfonic acid)
- PFBS (perfluorobutane sulfonic acid)
Samples must be analysed using a method based on US EPA Method 1633A, with reporting limits designed to detect PFAS at very low concentrations.
Who does the Order affect?
The Order applies to:
- Licensed landfills in NSW – for monitoring of leachate and groundwater (or surface water where applicable).; and
- Licensed STPs – monitoring to better understand PFAS concentrations entering, moving through and leaving wastewater treatment systems
What is being tested?
Under the Order, operators will be required to:
- For landfills, monitoring of leachate must occur once per year, and for downgradient groundwater, four times per year on a quarterly basis.
- If a landfill doesn’t have an appropriate groundwater monitoring location, then a surface water monitoring location can be used.
- For STP’s, monitoring of treated effluent must be conducted on a quarterly basis.
- Analyse samples for PFOA, PFOS, PFHxS and PFBS using an approved analytical method; and
- Report results to the NSW EPA and retain supporting records.
What are the likely outcomes?
Given the very low reporting limits required under the Order, PFAS detection is expected at many sites with historical connections to municipal, industrial or commercial waste streams.
Already, questions are moving from ‘is PFAS present?’ to the more practical concern of ‘what is the most appropriate way to manage PFAS at this site?’
The best management approach will be determined by a range of factors, including:
- PFAS concentrations and types detected;
- existing treatment infrastructure;
- discharge requirements;
- future regulatory expectations; and
- site-specific operational considerations.
What can councils and operators do now?
While the new requirements do not commence until October of this year, there are several practical steps organisations can consider now.
Review potential PFAS sources: Understanding historical waste acceptance, industrial inputs, catchment characteristics and site operations can help build a clearer picture of where PFAS may be entering or moving through a facility. Developing a conceptual understanding of PFAS sources and pathways is consistent with established guidance, including Australia’s NEMP 3.1.
Review existing monitoring information: Existing groundwater, leachate or wastewater data may already provide valuable insights. Where appropriate, additional sampling before the Order commences may also help establish a clearer understanding of current site conditions.
Consider future treatment pathways: Once monitoring data is available, some sites may require additional PFAS management strategies. An early understanding of available treatment options allows operators to plan rather than react.
Planning ahead for PFAS management
Across Australia and internationally, operators are moving from PFAS detection towards practical management strategies.
Technologies such as EPOC Enviro’s SAFF® may be a good PFAS remediation fit for your application. But the key first step is understanding the challenge.
The NSW EPA Order provides an important opportunity for councils and operators to build a clearer understanding of PFAS chemistries present in site waters and develop a considered approach to their future management.
Got questions?
Our team are available to walk you through these regulatory changes and can provide you with practical guidance as well as obligation free information on how SAFF® technology performs in landfill and STP environments. Contact: info@epocenviro.com .
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