Alphabetical According to Lead Presenter/Author. Posters are listed after the session abstracts.
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Exposing Perspectives on Exposure and Risk
Christy A. Barlow, Ph.D., Associate Principal, Manager of Toxicology, GZA, Boulder, CO, firstname.lastname@example.org
Recently, a growing public awareness of PFAS detection in U.S. drinking water has hastened demand for enforceable PFAS drinking water standards. Although the U.S. Environmental Protection Agency (EPA) has considered risk-based standards for the two most well-known PFAS, perfluorooactanoic acid (PFOA) and perflouorooctanesulfonic acid (PFOS), individual states have largely been left to develop and enforce PFAS standards or guidelines for their drinking water. As a result, there is significant variation across State and Federal agencies with respect to which PFAS are regulated and at what levels. This wide variation is sowing confusion among the general population and within industry and is reflective of discordant risk assessment principles and practices utilized by differing regulatory agencies. Here, we would present the primary considerations and variables driving uncertainty in the risk assessments of individual PFAS and identify key toxicological factors that should be considered by agencies when setting general guidelines or enforceable maximum contaminant levels (MCLs).
Statewide PFAS Sampling of Wastewater Treatment Plants in Michigan
Dorin Bogdan, Ph.D., AECOM, PFAS Technical Practice Group Leader, Grand Rapids, MI, Dorin.Bogdan@aecom.com
Per- and Polyfluoroalkyl (PFAS) are an emerging contaminant class of human-made chemicals used in commercial products in the late 1940s. Industries using PFAS include automotive, aviation, aerospace and defense, biocides, cable and wiring, construction, electronics, energy, firefighting, food processing, mining, metal plating, medical, paper and packaging, semiconductors, and apparel (OECD, 2013; UNEP, 2013). While some PFAS undergo partial biotic or abiotic degradation to stable PFAS end-compounds, most do not demonstrate susceptibility to degradation and are highly persistent in the environment (Wang et al., 2017). As a result, these human-made chemicals are expected to be detected for decades in the environment and are spreading to areas far from their original release.
While Wastewater Treatment Plants (WWTPs) are not the source of PFAS, they are a natural point of collection and could serve as a key location for control and potential removal to mitigate their release into the environment. Conventional sewage treatment methods do not efficiently remove PFAS, and effluents discharged from wastewater treatment plants and biosolids applied to the land for beneficial reuse have been identified as two of the main known PFAS release pathways into the environment by the Interstate Technology and Regulatory Council (ITRC) (ITRC, 2017). Varying concentrations of perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid (PFOA), and other PFAS have been measured in surface waters and biota in Wisconsin (Kannan, 2001, Ye, 2008, Stahl, 2014, Williams, 2016).
PFAS was identified in WWTPs since the early 2000s during the 3M-sponsored Multi-City Study from Alabama, Tennessee, Georgia, and Florida. PFAS were also later identified in WWTPs from Minnesota, Iowa, California, Illinois, New York, Kentucky, Georgia, and Michigan (Boulanger, 2005; Higgins, 2005; Schultz, 2006; Sinclair, 2006; Loganathan, 2007; Sepulvado, 2011; Houtz, 2016). To better evaluate the potential PFAS impacts to the WWTP and agricultural fields that received biosolids, a statewide sampling of WWTPs was performed in Michigan.
In Michigan, there are over 90 WWTPs that receive industrial wastewater under the Industrial Pretreatment Program (IPP). To evaluate the potential PFAS presence in the WWTPs, Michigan Department of Environmental Great Lakes and Energy (EGLE) requested WWTPs that are receiving industrial wastewater that could potentially be impacted by PFAS to sample their discharge effluents and assess the possible sources of PFAS. Initial sampling in 2017 performed for a WWTP was found to have a PFOS concentration of 2,500 ng/L in the effluent and 2,100 µg/kg in the biosolids. A sampling of the effluent was conducted for a total of 75 WWTPs were sampled at least annually. A subset of 42 WWTPs was further evaluated to better understand mass balance, including influent, effluent, and biosolids. The impact of treatment processes was also evaluated for select WWTPs. The study evaluated the occurrence of 24 PFAS compounds. The current statewide PFAS sampling study provides a robust evaluation of potential PFAS impacts to the WWTPs and biosolids from Michigan. A summary of the entire program will be presented along with the PFAS concentrations from various industries. An overview of several PFAS source reduction case studies will also be presented.
Dr. Bogdan is an AECOM PFAS technical expert and has authored many technical papers for national conferences on this topic. Dr. Bogdan is an environmental engineer with over 11 years of experience in soil, sediments, and groundwater remediation, innovative technologies, and hazardous waste. Dr. Bogdan’s has worked on dozens of PFAS projects, applying his depth of experience to the unique challenges associated with analytical testing and methodologies, environmental fate and transport, site characterization, conceptual site models, bioaccumulation in the food webs, regulatory negotiation, and remedial technologies.
Developing a Robust Fate and Transport Model - Case Study
John M. Cuthbertson, CPG, AECOM, North America Industrial and Oil & Gas PFAS Lead, Grand Rapids, MI, John.Cuthbertson@aecom.com
Per- and Polyfluoroalkyl substances (PFAS) are an emerging contaminant class of human-made chemicals that were first developed in the late 1930s and started to be used in commercial products in the late 1940s. Due to their unique chemical properties, PFAS were used as wetting agents in many wet-chemical processes of surface finishing, including metal plating. PFAS has been used in the chrome plating industry due to its high chemical stability in conjunction with the powerful oxidizers, chromium (VI), and sulfuric acids. Wetting agents containing PFAS have an added benefit as a mist and vapor suppressant that protect the workers from toxic vapors, eliminating the need for costly ventilation. Plating facilities have been identified as a significant source of PFAS to wastewater treatment plants (WWTP), with Perfluorooctane sulfonic acid (PFOS) being the primary PFAS compound detected. The use of wetting agents at plating facilities is well documented. During a survey in California from 2006, a total of 124 out of 224 Cr(VI) chrome platers used FumertrolTM 140, a wetting agent that contains PFOS. Studies performed in 2008-2009 in Minnesota, Ilinois, and Ohio also identified PFOS as the primary PFAS detected and often associated with FumertrolTM 140. During current evaluations of industrial sources to WWTP in Michigan, the majority PFOS detection at WWTPs has been associated with plating and metal finishers facilities. While PFOS has been removed from most wetting agents formulations, it has been replaced with 6:2 Fluorotelomer sulfonic acid (6:2 FTSA): however, PFOS is still being detected in their effluents if it was used historically. To our knowledge, a robust environmental evaluation has not been completed at plating facilities in the United States to this date. To that end, a robust Conceptual Site Model (CSM) was completed at a former chrome plating facility in Michigan to better understand the complex fate and transport of these mist suppressant PFAS mixtures that were released to the environment.
Effluent from a former chrome plating facility (Facility) was identified as discharging PFAS to the local WWTP under Michigan’s Industrial Pretreatment Program (IPP). The Facility was operating a pump and treat system to reduce off-site migration of a Nickel and Cr(VI) groundwater plume. Captured groundwater was discharged to the WWTP for treatment of the metals. During sampling required as part of the IPP program, this Facility was identified as the primary source of PFOS being discharged to the WWTP with PFOS being detected at 8,000 ng/L. Initial response activities included sampling over 75 residential drinking water wells downgradient of the Facility and the installation of an interim PFAS treatment system to treat the pump and treat groundwater effluent as required by the WWTP. PFOS was detected in multiple residential wells at concentrations greater than 1,000 ng/L which led to an extensive remedial investigation which included 75 nested wells in 25 locations. Surface water bodies were also sampled at 10 locations including two ponds that are used for irrigation of agricultural fields. The impact at the facility from previous industrial activities was also evaluated by sampling a total of 15 existing monitoring wells and collection of 25 soil samples from former settling ponds and sludge drying beds. A total of over 500 samples were collected during the multiple phases of this investigation.
This presentation will review and discuss regulatory challenges facing industrial and manufacturing facilities dealing with PFAS impact in effluent and groundwater nationally, and then discuss how that may affect facilities Wisconsin. A case study will then be presented to demonstrate both challenges a former chrome plating facility was forced to deal with and the real-life solutions that were implemented to maintain compliance. This case study will include overview of interim corrective measures to treat a PFAS impacted effluent stream, investigation phases and corresponding analytical results, a review of sensitive receptors, enhanced plume delineation using a 3D model, fate and transport mechanisms of PFAS chemicals within both soils and groundwater, the current CSM at the facility, and path forward.
John Cuthbertson serves as AECOM’s North America Industrial and Oil & Gas PFAS Lead and Central Region PFAS Practice Lead. He has over 28 years of environmental consulting experience supporting oil and gas, chemical, and industrial clients. Mr. Cuthbertson primary focus during the past four years has been PFAS and during this time has managed dozens of projects across North America involving various PFAS constituents and is experienced in analytical testing and methodologies, environmental fate and transport, assessment and investigation, and treatment technologies. Mr. Cuthbertson offers a compelling synergy of technical expertise, regulatory knowledge, and negotiating experience that facilitates development of sound strategies for site characterization, remediation, and closure effectively balancing risk, exposure, and cost.
Conceptual Site Model for PFAS at the Nine Springs Wastewater Treatment Plant
Martin Griffin, Madison Metropolitan Sewerage District, Director of Ecosystem Services, Madison, WI, email@example.com; Mike Ursin, PG, TRC Companies, Senior Project Manager, Madison, WI, firstname.lastname@example.org
Wastewater treatment plants (WWTPs) are receivers of per- and polyfluoroalkyl substances (PFAS) from society’s sanitary waste and potentially from industrial dischargers who historically used or continue to use PFAS compounds in their manufacturing processes or products. Because our knowledge around PFAS are emerging, the conventional primary and secondary treatment processes at municipal WWTPs are not designed to remove PFAS. In fact, perfluoroalkyl acids such as perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) are sometimes detected at higher concentrations in the effluent leaving a WWTP than the influent coming into a WWTP. Transformation of polyfluorinated precursor compounds from oxidation, hydrolysis, and other reactions from a WWTP’s processes can account for the increased perfluorinated mass in the effluent. Additionally, PFAS has been found in the biosolids generated by WWTPs. The concentration of PFAS in biosolids can be significant if a major industrial source of PFAS, such as a chrome plating operation, discharges to the WWTP.
The Madison Metropolitan Sewerage District (District) partnered with TRC to evaluate the current scientific literature on the fate and transport of PFAS in the environment and WWTPs. The results are summarized in a Fate and Transport Report and Conceptual Site Model specific to the District’s Nine Springs Wastewater Treatment facility (Nine Springs plant). This presentation will describe the key findings of the study, including the PFAS transformations that may occur in processes within the Nine Springs plant and the anticipated impacts of PFAS in land applied biosolids.
Martin Griffin, PE, Director of Ecosystem Services, Madison Metropolitan Sewerage District
Martye has always been about the ‘WE’ in ‘WATER’ and how human decisions impact water quality. He received his graduate degree in biology examining the impacts of excess nutrients on coastal ecosystems at the Marine Biological Laboratory in Woods Hole, Massachusetts, and has over 20 years of experience working in the public and private sector looking holistically at the interaction between human land use and water quality. With increasing societal and regulatory pressure to produce cleaner water than ever, It costs more to clean water after it is polluted than preventing the pollution in the first place. Martye focuses on solving problems adaptively as a way to “move at the speed of trust” and is just the way we have to do business.
Mike Ursin, PG, Senior Project Manager, TRC Companies
Mike Ursin, PG, has spent the last 12 years of his career as an environmental consultant supporting clients in the industrial, commercial, real estate, and government sectors as they navigate environmental issues related to their business operations, including addressing PFAS and other emerging contaminants. His extensive experience includes environmental investigations, remediation, environmental compliance, geotechnical investigations, contaminated material management, NEPA, client and regulatory communication, and building working relationships with clients. Mike is a Wisconsin-licensed Professional Geologist, NR 712.03(1) Hydrogeologist, and is a member of TRC’s Emerging Contaminant and Phase I ESA CORE teams.
The Promise and Pitfalls of In-Situ Carbon Immobilization of PFAS – Two Case Studies from Michigan
Len Mankowski, MEM, Wood Environment & Infrastructure Solutions, Inc., Senior Geologist, Traverse City, MI, email@example.com
PFAS are an emerging contaminant of concern that present significant environmental challenges. The fate and transport of PFAS in the environment is complicated by their hydrophobic carbon-fluorine “tail” and a charged, hydrophyllic “head.” Sorption of PFAS in soil is found to vary considerably (wide range of organic carbon-water partitioning coefficients; e.g., McGuire, et al, 2015). Sorption is also complicated by preferred sorption of non-PFAS compounds to the soil matrix (e.g., co-contaminants such as volatile organic compounds). Internal studies by Wood have indicated that cation exchange capacity, total organic carbon, pH and grain size may influence sorption, leaching and/or retardation rates of PFAS in the subsurface.
The 2018 Interstate Technology Regulatory Council (ITRC) fact sheets identify sorption and in-situ stabilization of PFAS in the ground via addition of carbon-based (and non-carbon-based) amendments as a partially demonstrated, available remediation technology. Granular activated carbon (GAC) and powdered activated carbon (PAC) are demonstrated technologies and bio-char is a partially demonstrated technology to remove PFAS from groundwater ex-situ. The long-term functionality of in-situ sorptive media to immobilize PFAS remains a data gap.
Despite significant literature showing that low-grade carbon products suffer from many limitations associated with PFAS sorption, Wood, at the request of our clients, provided oversite and performance monitoring testing for three pilot tests involving in-situ carbon-based stabilization of PFAS at two different Michigan sites in 2018. During the first pilot test, PlumeStop® was injected into a co-located, low-level tetrachloroethylene (PCE) plume downgradient of a former fire-training area. Two months post injection, perfluorooctanesulfonic acid (PFOS) and PCE were not detected in downgradient groundwater.
Pilot testing at the second site involved two tests using a biochar (BAMTM) in the PFAS source area surrounding a former tannery that burned down in 2005. Historical tannery use has impacted water quality (i.e., total organics and metals). In one test area the biochar was injected into the saturated system. At 7 days post-injection, PFOS concentrations declined by 19% (coarse spacing; result is comparable to change observed in upgradient wells) to 96% (tight spacing) in groundwater. For the second test the biochar was separately mixed into a 10x10-foot area. At 7 days post-mixing, groundwater PFOS concentrations were reduced by 97%.
Neither amendments tested achieved homogenous distribution when delivered by injection and performance monitoring is ongoing. The collected data do not yet demonstrate the effectiveness of these products to stabilize PFAS in soil or groundwater but will provide long-term Site-specific case studies for consideration in future feasibility studies to address PFAS.
Len Mankowski is a Senior Geologist at Wood Environment & Infrastructure Solutions (Wood) with over 14 years of hydrogeologic characterization and remediation experience at contaminated Sites across Michigan and the Midwest. His primary areas of expertise include: innovative remedial investigation techniques; hydrogeologic and conceptual site model development; risk characterization; and conceptual remedial design/technology assessments. Mr. Mankowski earned a Bachelor of Science degree in applied geophysics in 1999 and a Master of Science in Geology in 2003 from Michigan Technological University, where he also worked as an instructor prior to entering consulting. Mr. Mankowski has published and/or presented several papers on innovative characterization and remediation approaches applied at Sites in Michigan (including the Wickes TCE Plume). Mr. Mankowski lives near Suttons Bay, Michigan and is also a board member, coordinator and coach for the Leelanau County youth soccer program.
Colloidal Activated Carbon used to Reduce PFAS and PCE Concentrations in Groundwater to Below Detection Limits at a Michigan National Guard Site
Ryan Moore, REGENESIS Bioremediation, Valparaiso, IN, firstname.lastname@example.org; Patricia Byrnes Lyman, Michigan Department of Military and Veteran Affairs, Lansing, MI, email@example.com
Camp Grayling in Crawford County, Michigan is a year-round training center for the Michigan Army National Guard. The Michigan Department of Military and Veteran Affairs (DMVA) have been remediating chlorinated solvents impact in the site groundwater from historical operations at the facility since the 1990’s. In 2016, the DMVA became aware of the potential contamination of PFAS from historical operations such as onsite firefighting training activities and began testing. PFAS was found commingled with a chlorinated solvent plume that was migrating towards the property boundary. The DMVA reviewed potential remedial options to test in the field such as pump and treat, but ultimately decided to test an in-situ reactive barrier application of colloidal activated carbon, an approach that is first of its kind in the State of Michigan.
Colloidal activated carbon was selected because of the expected rapid reductions of PFAS by removal from the dissolved mobile phase and well-established uses for chlorinated solvent sites. Colloidal activated carbon effectively increases the retardation factor of PFAS migration contaminants by multiple orders of magnitude and eliminates the exposure to down-gradient receptors. In addition, colloidal activated carbon was selected due to its expected lower total project costs when compared to operating a mechanical system over a similar time.
This presentation will review the project design considerations, field activities, and 1.5 years of post- application data. Additionally, the presentation will answer questions related to the distribution of the colloidal activated carbon in the subsurface and expected long-term efficacy at the site.
The project area was treated with a single application of colloidal activated carbon to address PFAS and chlorinated impacts in groundwater. Mass flux and predictive competitive sorption modeling was utilized to determine the appropriate amount of colloidal activated carbon required. The remediation solution was applied under low pressure (non-fracking) conditions using direct-push technology with separate soil cores and monitoring well gauging to determine distribution. Prior to treatment, total PFAS levels were detected in site groundwater samples above the USEPA drinking water advisory limit of 70 ng/L.
The mass flux and predictive competitive sorption modeling demonstrated a theoretical PFAS retardation span of greater than 50 years. Results from the field activities monitoring demonstrate distribution of the colloidal activated carbon has been achieved using low pressure injection methods. Furthermore, the post-application groundwater monitoring results demonstrate PFAS and chlorinated solvent concentrations have been reduced to below laboratory detection limits. The contaminant concentration reductions in groundwater were achieved within one month after the field activities and have been sustained for over a year and half. This study indicates that an in-situ application of colloidal activated carbon is a viable alternative to the established remediation method of a high-cost pump and treat system to address the risk associated with PFAS contamination at the site.
Programmatic Approach to Management of PFAS; Using Risk‐based Prioritization to Understand Liabilities
Shalene Thomas, Wood Technical Consulting Solutions (TCS), Global Emerging Contaminants Program Manager, Minneapolis, MN, Shalene.firstname.lastname@example.org; Andri Dahlmeier, MPCA, Project Manager, Minneapolis, MN
In 2002, the Minnesota Department of Health (MDH) partnered with the Minnesota Pollution control Agency (MPCA) to investigate PFAS in Minnesota. This work began with ground water and drinking water investigations at and near the 3M Cottage Grove plant and related legacy waste disposal sites in Washington County (east of St. Paul). Since 2002, MDH has: established and updated health‐based criteria for four different PFAS; developed analytical methods for environmental media, blood serum, and garden produce; conducted many community engagement activities; completed investigations at some fire training areas and chrome‐plating facilities; and completed fish monitoring of 93 lakes and rivers. As the MDH and the MPCA moves forward in evaluating PFAS across the State, they are taking a programmatic approach evaluating potential sources and managing and mitigating impacts to human health and the environment, where appropriate and necessary. The objective of this presentation is to outline the approach taken for that evaluation, share the results and lessons learned from the process, discuss the next steps in the program, and how the approach has applicability across sectors. This programmatic approach is not only invaluable for a State to determine potential sources of PFAS and efficiently manage and mitigate impacts, but it also can be modified and applied to an industrial portfolio to identify/mitigate unacceptable exposures and establish remediation reserves across a given set of assets.
The approach includes a multi‐phased plan to identify and evaluate potential locations across the State that may have been contaminated with PFAS. The first phase, potential source locations and candidate evaluation, established a basic framework and protocol to identify and evaluate potential PFAS locations. A pilot test of four counties was initially conducted to develop and test the protocol prior to roll‐out across the remaining 83 counties statewide. Businesses in each county were compared to North American Industry Classification System (NAICS) codes anticipated to be potential PFAS users, then addresses were geocoded using Geographical Information Systems (GIS), stored in a geodatabase and mapped. Potential pathway analysis was then performed using publicly available well information, surface water features, and aquifer sensitivity data. Next, a receptor evaluation was performed to determine relevant sensitive sub‐populations.
The second phase, location prioritization and selection, included a risk ranking evaluation of potential risk categories including sub‐categories of sources, pathways, and receptors. Each risk category was given a risk score that was added together for each location yielding a final location risk rank. Locations were then prioritized and location profiles were developed for the top‐ranked sites. The last phase, absence/presence determination is planned and will include biased sampling and analysis at top‐ranked sites to determine the absence or presence of PFAS at each location. Preliminary conceptual site models have been developed by location type and a risk communication plan has been drafted to support the roll‐out of the program. Several lessons have been learned through the protocol process. The pros and cons of the protocol process will be discussed as well as potential applicability to other types of industries.
Ms. Shalene Thomas, PMP, is the Emerging Contaminant Program Manager for Wood. She has more than 20 years of experience in environmental consulting that includes 11 years of experience supporting per- and polyfluoroalkyl substance (PFAS) evaluations. She has extensive program and project management, human health risk assessment, data management, GIS and 3D visualization and animation experience and has supported State, Federal and industrial clients with PFAS evaluations. She serves as Wood’s PFAS Work Group Lead and has supported PFAS projects in 32 different states in 9 of the 10 USEPA regions as well as in Australia and Canada.
Environmental Forensics Applied to PFAS – What Does My Data Tell Me
Jeff Tracy, MEM, PG, Geosyntec Consultants, Inc., Senior Geologist, Mequon, WI, JTracy@geosyntec.com
Geosyntec will present a discussion of forensic analysis techniques we used at various sites across the US to evaluate PFAS releases. The objectives of forensic analysis are to identify source(s), determine when a release occurred, and allocation in a multi-source release. The forensic analyses tools will include:
• Indicator compound analysis, which may be used to evaluate specific PFAS production processes to infer age, source, and release mechanisms, for example:
• Certain PFAS compounds are often associated with the fluorochemical manufacturing industry and industrial facilities engaged in coatings and surface modification applications; others are often associated with the aqueous film forming foams used by fire fighters to extinguish hydrocarbon fires and mist/fume control agents used in the metal plating industry; and other compounds are often linked to waste sources such as landfills and waste water treatment plants.
• Review of different indicator compounds can provide information as to age,
manufacturing processes, product and use, or other information that can be used to
understand release characteristics.
• Composition analysis
• The ratio of PFAS compounds in a sample may demonstrate unique signatures originating from different sources and provide evidence of single or multiple receptor inputs.
• Use of graphical tools may show distinct PFAS “fingerprints” within discrete areas of investigation. These “fingerprints” may indicate the presence of single or multiple PFAS source zones.
• It may be possible to identify the probable source of a PFAS release by comparing the composition of samples to literature values or the known composition of source materials.
• Composition analysis my also reveal the evolution of a PFAS signature as it migrates from a single source due to the differing physiochemical properties of individual compounds and the conversion of polyfluorinated precursor compounds into fully fluorinated perfluoroalkyl acids.
• Isomeric Profiles
• Historically, PFAS compounds have been manufactured using one of two major processes; each process has distinct chemical fingerprints that can often be used to distinguish PFAS originating from one process or the other. By examining differences in the PFAS compounds it is possible to construct isomeric profiles that may be used to distinguish areas potentially impacted by different PFAS sources. This analysis may also be used to determine if individual PFAS compounds in a sample originated from a single, or multiple sources; or may help to identify a product associated with the release.
• Principal Component Analysis (PCA) is a statistical technique that can be used to uncover distinct modes of variability among various PFAS constituents analyzed in multiple samples. This analysis can guide further investigation of PFAS data and may help in the identification of different PFAS signatures within a dataset. These signatures, in turn, can provide insight into the sources and processes behind the observed PFAS concentrations.
Geosyntec used these techniques to evaluate PFAS at sites throughout the US. Due to confidentiality requirements, we will present hypothetical example sites based on sites and data where Geosyntec provided forensic services.
Jeff Tracy is a Licensed Professional Geologist in Wisconsin with over 25 years of experience in soil and groundwater quality investigation, remedial action plan development and implementation; environmental project management, primarily in the practice of owner’s representation for site and portfolio management; environmental due diligence; spill response and management; demolition planning and management; and brownfields redevelopment. Jeff’s primary experience is remediating petroleum and chlorinated compound contaminated media at former and operating manufacturing facilities, Superfund and State-lead sites, and private party sites.
Analytical Methods and Data Validation: Caveat Emptor
Mark Westra, GZA, Brookfield, WI; Katherine McDonald, GZA, Brookfield, WI, Katherine.McDonald@gza.com
With all of the attention on PFAS in drinking water, biosolids, and soil in the US, there has been a rush for laboratories to join the PFAS analytical band wagon. Laboratory analysis for PFAS is a relatively recent development, and there are different analytical methods, analyte lists, and laboratory calibration approaches. Analytical methods are evolving, and standardized analytical methods for soil and groundwater have lagged. US EPA published a method for finished drinking water, but the preferred analytical methods for non-drinking water matrices (soil, groundwater, biosolids, leachate) vary depending on the regulatory program/entity and sometimes the data user. EPA plans to publish more prescriptive methods for non-drinking water matrices, but will these improve data quality? In the interim, how should people designing PFAS studies approach method selection, quality control, and data evaluation/validation?
Implications of PFAS on Business Transactions: Moving from the Theoretical to the Practical
Edward B Witte, Godfrey & Kahn, s.c., Attorney Shareholder, Milwaukee, WI, email@example.com
2018 and 2019 represented a period of coming to grips with the reality of per- and polyfluoroalkyl substances (PFAS). In the absence of federal regulation to lead and guide state standards for PFAS, states like Wisconsin have scrambled to develop rules and programs to address these emerging contaminants.
In 2020, the business community will transition into the realm of practical management of PFAS in business transactions, including in mergers and acquisitions, real estate transfers, and secured property financing. However, until recently, there has been little or no attention paid to the possible current or historical presence of PFAS in transactional due diligence. Evolving regulations indicate that emerging contaminants like PFAS will be regulated as hazardous substances and therefore will be the subject of future investigation and remedial actions. Given the significant costs associated with remediating these contaminants and the striking absence in many jurisdictions of specific cleanup targets for these substances, parties to transactions will need to intelligently and practically approach the potential presence of PFAS during due diligence in M&A, real estate, and corporate financing transactions. This seminar presentation will cover the details of PFAS in the environmental due diligence context, buyer expectations and seller sensitivities, working with consultants and regulators to address contaminants that may not have specific published cleanup standards, practical considerations on negotiating and documenting known and unknown risk in contractual agreements, use of tools including the “new” Wisconsin Voluntary Liability Exemption act and environmental insurance, and managing risks post-closing. In addition to these transactional considerations, this presentation will also address PFAS contamination at closed clean-up sites, including landfills. Potential re-opening of closed sites will lead to liability for potentially responsible parties at those sites. If the federal U.S.EPA follows through on plans to recognize certain PFAS chemicals as hazardous substances under CERCLA, such a step could send shock waves for past CERCLA settlements and open the door to future litigation. The focus of the presentation will be from the perspective of a lawyer but will address and inform consulting engineers on ways to maximize their involvement and value in business transactions and a shifting regulatory landscape.
Edward (Ned) B. Witte is a shareholder in the Godfrey & Kahn Environmental Strategies Practice Group. Ned has extensive experience in environmental due diligence and liability allocation in business transactions, defense enforcement actions and pursuing environmental contractual rights against third parties, the development and redevelopment of contaminated properties, including Brownfields, and coordinating Superfund site response activities. Ned frequently writes and speaks concerning Per-and Polyfluoroalkyl substances, or PFAS. Ned represents clients at several PFAS sites in Wisconsin (as identified on Wisconsin's BRRTS database). Ned Witte was the 2016 Best Lawyers® Environmental Law “Lawyer of the Year” in Milwaukee.
Comparison of Per- and Polyfluoroalkyl Substances (PFAS) in Biosolid and Biochar for the Remediation Application
Caroline Rose Alukkal, Purdue University, PhD Scholar, West Lafayette, IN, firstname.lastname@example.org
The conventional wastewater treatment systems result in the selective partitioning of PFAS into biosolids. Due to the nutrient-rich organic composition of biosolids, they are increasingly land applied in urban and suburban settings in order to enhance soil quality and plant growth, but also as a method of waste handling and carbon storage. However, research in the past few decades has shown that biosolids are acting as a secondary source of many contaminants of emerging concern, including PFAS. This study is a comparison of PFAS in biosolid and the corresponding pyrolyzed product. The release potential of PFAS from biosolid and biochar is also compared in order to enable the quantification of possessed environmental risk. The inertness of the material along with the comparable plant growth enhancement property as that of biosolids proposes the biochar as a potential candidate for PFAS remediation through sorption. This technology has added advantages of long term sequestration of carbon and easing the handling of millions of tons of biosolids generated in the United States every year.
Caroline Rose Alukkal is a Ph.D scholar at Purdue University with research centered on the quantification and remediation of PFAS. She has gained a Bachelor’s Degree in Biotechnology Engineering and Master’s Degree in Environmental Science and Engineering. She is actively involved in the research on remediation technologies from the Under-Graduate studies. She loves learning new technologies and taking up the challenges as they result in creative practical solutions. Her happiness lies in the conservation of environment innovatively but simple.
Aquatic Chemistry at UW-Madison: Fate and Transformation of Organic Contaminants
Sarah Balgooyen, Ph.D, Remucal Research Group, University of Wisconsin-Madison, Madison, WI, email@example.com
The Remucal research group investigates processes that degrade organic contaminants in natural and engineered systems. Organic contaminants, such as pesticides, pharmaceuticals, industrial chemicals, enter the environment through stormwater, runoff, and wastewater. These compounds may degrade in the environment via photochemical reactions (reaction with sunlight), microbial processes, or oxidation via naturally occurring minerals. Certain compounds like PFAS (per- and polyfluoroalkyl substances) do not have any known degradation pathways, and therefore pose a serious concern to human and environmental health. In engineered systems, processes are designed to remove certain organic contaminants. In the Remucal research group, we study how these organic contaminants behave in the environment and their potential treatment processes.
Specific research projects vary widely in the Remucal group. Some projects are localized in Wisconsin, such as the investigation of PFAS contamination from a fire products facility in Marinette, WI; the use of herbicide 2, 4-dichlorophenoxyacetic acid (2, 4-D) on lakes across Wisconsin to remove Eurasian Watermilfoil; and the application of lampricides to tributaries of Lake Michigan to reduce populations of the invasive sea lamprey. Other research projects involve treatment of contaminants that can be applied more generally. These projects include the alterations to traditional chlorination treatments in drinking water facilities and reduction of harmful disinfection byproducts that are formed in water treatment; photochemical degradation of pharmaceuticals in natural waters; and removal of phenolic contaminants by oxidative degradation, which may be used to treat contaminated stormwater runoff.