Definition of “Treatment”
Shortly after we published our report, we needed to use different terminology to refer to the facilities that process sewage. In January, we began to use the term Sewage Treatment Plant (STP) rather than Wastewater Treatment Plant (WWTP). We did this because “Wastewater Treatment Plant” implies that these facilities treat a broad range of wastes. They don’t. They are designed, managed, and regulated to treat domestic sewage.
Recently, Laura Orlando, Senior Scientist at Just Zero, delivered a presentation on landfill leachate treatment technology to our coalition. Her presentation raised the very important question of what the term “treatment” means. Laura shared a list of three guiding questions that can be used to clarify what it means to “treat” a waste stream and understand what a treatment approach offers. They are:
- What are the goals of the treatment?
- How are we going to evaluate the treatment’s effectiveness?
- What substances are we treating for?
It was by thinking about these types of questions that our collaborative first identified the Leachate Loophole, and later these same types of questions helped us realize the need to shift our language from “wastewater treatment plants” to “sewage treatment plants.” The goal of an STP is to treat human waste. It is evaluated based on its effectiveness at removing or reducing a few chemical and biological substances that are indicators of human waste. The answers to Laura’s questions explain why landfill leachate shouldn’t be sent to these facilities.
In New York State, the Department of Environmental Conservation (DEC) in 2023 announced its intention to open a rule-making on onsite leachate treatment and disposal. Recent NYS guidance on PFOA, PFOS, and 1,4-Dioxane were DEC’s springboard for that action. Our collaborative has also engaged with municipalities such as the Town of Hurley and City of Kingston to address leachate disposal, and those conversations have centered on PFAS. As a preamble to her presentation, Laura pointed out that the current conversation about leachate treatment is already limited to PFAS, ignoring potentially thousands of chemicals that are present in landfill leachate. This fact isn’t usually laid clear, because the term “leachate treatment” is used, rather than something like “PFAS removal.”
Developing more responsible ways of managing landfill leachate is not a trivial process, and is not merely a question of what to do about PFAS. Even as we take steps forward to improve leachate treatment, we need to take a step back and ask whether our system of dumping waste into landfills can continue to serve us at all. Will it ever be possible to design and fund leachate treatment systems that truly neutralize the thousands of chemicals currently buried in landfills? Is it feasible to expect that we can produce a treated leachate that supports healthy rivers and drinking water supplies?
Our landfills will be around for the forseeable future, and will discharge toxic chemicals for decades. It is utterly essential that we develop the best leachate treatment systems we possibly can. But we can’t stop with that. We must also do as much as we can to reduce leachate flows by closing landfills.