As the debate around per- and polyfluoroalkyl substances (PFAS) management continues to unfold across Australia, NSW has moved to introduce a new monitoring order across the state, with the potential for management measures of the ‘forever chemical’ to be develop as a result.
The NSW Environment Protection Authority has released the Proposed PFAS Monitoring Chemical Control Order (CCO) and, if adopted, quarterly monitoring of PFAS in landfill leachate and sewage treatment plant effluent will become a requirement across NSW.
AWA Industrial Water & Trade Waste Specialist Network member Sharon Armstrong and Chair Deena Diedricks agree that the proposal represents both regulatory progression and operational challenges – particularly for regional councils.
Armstrong said proposed quarterly requirement carries practical weight.
“If adopted, water operators will need to do quarterly monitoring. And this can have a large impact on treatment plants in regional NSW, including sampling and lab testing,” she said.
For metropolitan utilities, expanding monitoring programs will require coordination and resourcing. For smaller regional operators, laboratory access, sampling protocols, data interpretation and budget capacity present sharper constraints.
Deidricks said that, once data is collected, expectations shift, as monitoring informs understanding and decision-making. Over time, that may lead to management requirements or source control obligations upstream.
“Once you start monitoring something and gathering information, the next obvious step is determining what management, if any, is required, for example the requirement to do source control and that has a knock-on impact for service providers, local government and businesses,” she said.
Deidricks said if monitoring does begin, management requirements may follow, and utilities are likely to examine identifiable point sources within their catchments.
“From a trade waste perspective, the lowest hanging fruit will be the known large industrial wastewater contributors of PFAS that are discharging into those catchments,” she said. “It may be a requirement to start managing point sources of PFAS to the network rather than tackling the more diffuse inputs from domestic wastewater given the ubiquitous nature of PFAS in the domestic catchment.”
For many regional councils, the shift may create an internal systems challenge. Councils frequently operate both landfills and sewage treatment plants, and landfill leachate discharged concentrates PFAS within council-managed infrastructure.
“You’ve got regional landfills and sewage treatment plants run by councils where the PFAS-laden material from the community is ending up. The different areas are going to have to work together to manage this moving forward, while being mindful of community, environmental and budget impacts,” Deidricks said.
The monitoring requirement also intersects with recycled water schemes – a cornerstone of water security and nutrient management strategies in many regions.
“Another domino effect is with the recycled water schemes that some of these wastewater treatment plants also run,” Armstrong says.
Utilities operating irrigation or land application schemes would need to assess how PFAS data interacts with reuse guidelines, groundwater considerations and community confidence, Armstrong said.
“You’ve then got to consider: what is your monitoring resource? Where’s it going? What are you using it for? So if you’re irrigating your local council playing fields, then what does that add to the monitoring, or what impact does that have in terms of groundwater infiltration?”
Diedricks said the regulatory interpretation of monitoring results will be critical.
“If regulation evolves and doesn't allow reuse options due to PFAS levels, then what will that mean for regional councils that are landlocked and are using recycled water schemes or land application as their main effluent disposal methods?” Diedricks asked.
For both Deidricks and Armstrong, long-term effectiveness in PFAS remediation depends on upstream control.
“In NSW, we’ve always had a big push on source control. I think that’s key,” Armstrong said.
“Monitoring of products and chemicals needs to be stronger, otherwise we just keep pushing this stuff down the drain and relying on end of pipe to fix the problem.”
Diedricks frames PFAS as a systemic challenge rather than a water utility issue alone.
“It’s a societal problem. We live in a throw-away, consumer society. But there’s also a legacy issue. These chemicals are here, already in our homes and industries. You can restrict them coming into the country and phase them out, but we’ll have this problem ongoing. There’s a long tail to it,” she said.
Deidricks said that while there are small pilots looking at technologies for PFAS removal, scale up is an issue, as is resourcing within regional councils.
“At the end of the day, a big part of this problem comes down to money. Who’s going to pay to manage this and remove it from our water cycle?” she says.
While fiscal accountability is discussed, Armstrong said it will be important to make sure regional councils are supported through any new monitoring or management requirements.
“In NSW, we’re struggling with shortage of skilled frontline staff in the water industry – getting people to stay in the industry and to come and work in regional areas is already tricky, without also needing new expertise,” Armstrong says.
“If we’re concerned about a remote community trying to run a recycled water system effectively and meet guidelines, we’ll have more pressure on our workforce still in tackling PFAS.”
As the EPA considers submissions and finalises its position, the monitoring order marks the beginning of a new evidence base for the sector. What follows will depend on how that data is interpreted, how responsibilities are allocated and how costs are shared.
Interested in learning more about AWA’s Specialist Networks? Take a look at the expertise areas shaping current discussions here.