Per-and polyfluoroalkyl substances (PFAS) are a class of synthetic chemicals with unique properties, such as repelling oil and water and resisting heat, that has made them useful for a wide range of applications and consumer products. This group includes compounds such as PFOA, PFOS, PFNA, PFHxS, PFDA, PFDoA, PFBA, PFBS, PFHxA, PFUnDA, and many more. Among these, perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) are two of the most commonly used and most persistent in the environment.
PFAS are often referred to as “forever chemicals” due to their resistance to natural degradation/breakdown. These characteristics can make site remediation both challenging and expensive.
The Ubiquity and Impacts of PFAS
A common misconception is that PFAS are only found in non-stick pans and firefighting foam. In reality, these chemicals are present in a wide range of products, including, but not limited to:
- Food packaging: grease-resistant coatings
- Textiles: fireproofing and waterproofing
- Paper products: flame retardant
- Electronics: semiconductor manufacturing
Given their widespread use and resistance to breakdown, PFAS pose significant challenges in environmental assessments, especially for properties with current or historical manufacturing operations. PFAS are highly mobile in the environment and can contaminate soil, groundwater, and water bodies, and have even been found at elevated concentrations in rainwater. They also tend to accumulate in the tissues of living organisms (bioaccumulation). Studies have identified potential links between PFAS exposure and various health risks, including liver damage, thyroid disease, hormone disruption, and increased cholesterol and blood pressure.
Regulatory Framework and Implications
The regulatory landscape for PFAS is evolving. The United States Environmental Protection Agency (USEPA) finalized a drinking water regulation on April 10, 2024, which established legally enforceable levels, called Maximum Contaminant Levels (MCLs), for six per- and polyfluoroalkyl substances (PFAS) in drinking water (PFOA, PFOS, PFNA, HFPO-DA, PFHxS, and PFBS).
On April 19, 2024, the USEPA finalized a rule designating two widely used PFAS (PFOA and PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as “Superfund.” Under CERCLA, releases of PFOA and PFAS exceeding one pound within a 24-hour period must be reported. This designation allows the EPA to enforce cleanup and remediation of PFAS-contaminated sites, with significant implications for property owners, developers, and lending institutions.
USEPA also issued a separate CERCLA enforcement discretion policy, which indicates that enforcement will be focused on those who significantly contributed to the release of PFAS to the environment.
PFAS Detection and Remediation Techniques
Due to their complex chemical properties and often low concentration levels (parts per trillion), detecting and assessing PFAS in soils and groundwater requires sophisticated techniques:
- Liquid Chromatograph-Tandem Mass Spectrometry (LC-MS/MS): The gold standard for detecting and quantifying PFAS, capable of identifying low concentrations.
- Solid Phase Extraction (SPE): Concentrates PFAS from large water samples to enhance detection limits.
- High-Performance Liquid Chromatography (HPLC): Separates PFAS compounds before detection by mass spectrometry.
- Ion Chromatography (IC): Separates PFAS based on their ionic properties, complementing LC-MS/MS.
Remediation Solutions
Effective PFAS remediation methods include:
For Water Sources
- Activated Carbon Adsorption: Widely used, but can require frequent replacement/retreatment.
- Ion Exchange Resins: Effective, but requires careful disposal.
- Reverse Osmosis: Highly effective but energy intensive.
- Advanced Oxidation Processes (AOPs): Degrades PFAS, but with high operational costs.
- Electrochemical Oxidation: Similar to AOPs, with high energy requirements.
For Soil Wastes
- Thermal Desorption and Incineration: Completely destroys PFAS, but is costly and energy intensive.
- Soil Washing: Treats soil by washing and then treating the wash water.
- Phytoremediation: Using plants to uptake and accumulate PFAS, may be suitable for low-level contamination, but is slow and requires replanting.
The Role of LCS (Lender Consulting Services), Inc. in PFAS Environmental Due Diligence
LCS, Inc. excels at all aspects of environmental due diligence and will be offering comprehensive solutions tailored to meet the unique challenges posed by emerging contaminants such as PFAS. Our team of experts is closely tracking the latest industry developments associated with PFAS sampling and risk assessment.
Expertise and Services
Expertise in Environmental Due Diligence and PFAS Management
- Decades of experience in environmental consulting and site investigations / remediation.
- A multidisciplinary team of scientists and researchers dedicated to understanding the complexities of PFAS.
- Interacting with state, federal, and/or local agencies on behalf of our clients.
- Continuous professional development and training to stay ahead of regulatory changes and understand emerging investigation/remediation technologies
Specific Services Offered
- PFAS Assessment: Site investigations to identify and quantify PFAS contamination using advanced analytical techniques.
- Risk Assessment: Evaluating potential environmental risks associated with PFAS presence to develop remediation strategies.
- Remediation Planning and Implementation: Developing and executing tailored remediation plans.
- Regulatory Compliance: Ensuring all activities comply with the latest federal, state, and local regulations, including CERCLA requirements.
- Monitoring and Reporting: Ongoing site monitoring and detailed reporting to track remediation progress.
Conclusion
As PFAS regulations tighten, it is crucial for stakeholders in the commercial real estate and environmental due diligence industries to stay informed and prepared. The new EPA ruling underscores the need for thorough environmental assessments and proactive remediation strategies to manage PFAS contamination effectively. LCS, Inc. remains a trusted partner in this field, providing expertise and tailored solutions to navigate the complexities of PFAS management, ensuring both environmental protection and regulatory compliance.
To learn more, reach out to Liz Mahoney, Director of Sales & Business Development today.
