pfas contamination: evolving state and federal regulatory...
TRANSCRIPT
PFAS Contamination: Evolving State and
Federal Regulatory Landscape, Litigation, and
Due Diligence in Transactions
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TUESDAY, AUGUST 7, 2018
Presenting a live 90-minute webinar with interactive Q&A
Russell Abell, P.G., LSP, Vice President, Sanborn Head & Associates, Concord, N.H.
Jeff B. Kray, Partner, Marten Law, Seattle
Matthew D. Thurlow, Partner, BakerHostetler, Washington, D.C.
Stephen Zemba, Ph.D., P.E., Project Director, Sanborn Head & Associates, Burlington, Vt.
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Introduction to Per- and Polyfluoroalkyl Substances (PFAS)
August 7, 2018
Stephen G. Zemba, Ph.D., P.E.
Sanborn Head & Associates, Inc.
Introduction to Per- and Polyfluoroalkyl Substances (PFAS)
▪ Basics (Sources and Characteristics)
▪ Exposure (Environmental Presence)
▪ Health Effects
6
PFAS – The BasicsPFAS = Per- and Poly- Fluorinated Alkylated (Fluoroalkyl)
Substances; also PFCs (subset) – Perfluorinated Compounds)
O
OH
F FF FFF F
F
F FFFFF F
perfluorooctanoic acid
(PFOA)
perfluorooctane sulfonic acid
(PFOS)
S
O
O
OH
F FF FFF F
F
F FFFFF F
F
F
Functional group
• Strong to
weak acids
• Hydrophilic
Fluorocarbon tail
• Strong bonds
• Hydrophobic
• Oleophobic
• Varying length
Also Note:
Precursors
Substitutes – Gen-X,
Adona, et al.
More than 3,000
PFAS compounds
identified
7
Environmental Sources of PFAS
8
• AFFF use for firefighting
• Military bases
• Airports
• Fire training/stations
• Refineries & other fire suppression
• Industrial/commercial facilities
• PFAS manufacturers
• Teflon manufacturers/Textile coaters
• Chromium platers
• Automotive & Electronics industries
• Car washes
• Household products/fabrics
• Stormwater runoff/street dust
• PFAS-containing wastes
• Landfills
• Wastewater treatment effluent/biosolids
PFAS Properties (PFOA and PFOS)
▪ Soluble in water (act as surfactants)▪ Persistent – Resistant to degradation▪ Low volatility ▪ Primary transport pathways
▪ Groundwater migration▪ Air deposition
▪ Primary exposure pathway▪ Ingestion of drinking water▪ Diet (e.g., fish) and dust
▪ Bioaccumulative (in human blood)
9
10
PFAS in Public Drinking WaterU.S. EPA 2013−2015 Unregulated Contaminant Monitoring Rule Sampling
Hu et al., ES&T Letters, August 2016, http://pubs.acs.org/doi/abs/10.1021/acs.estlett.6b00260
▪ Areas indicated watersheds
▪ Large water supplies (> 10,000 people)
▪ Estimated 6,000,000 people > EPA Health Advisory
PFAS – Health Concerns!?
11
▪ EPA Lifetime Health Advisory of 70 ppt issued May 19, 2016
▪ EPA PFAS Summit held May 22-23, 2018▪ MCL process to be investigated▪ PFOA and PFOS to be made CERCLA hazardous substances▪ Toxicity values for GenX and PFBS by end of summer
▪ ATSDR draft Toxicological Profile for Perfluoroalkyls contains Minimum Risk Levels (MRLs) for PFOA, PFOS, PFHxS, and PFNA
▪ Australian Expert Health Panel (May 7, 2018)▪ “… there is mostly limited, or in some cases no evidence, that human
exposure to PFAS is linked with human disease” and “there is no current evidence that suggests an increase in overall cancer risk”
▪ “… even though the evidence for PFAS exposure and links to health effects is very weak and inconsistent, important health effects for individuals exposed to PFAS cannot be ruled out based on the current evidence”
State Groundwater Standards/GuidelinesState PFOA PFOS Notes
Al, CA, CO, DE, FL, ME, NH, NY, RI
70 ng/LAdopted EPA Lifetime Health Advisory
Alaska and Illinois 400 ng/L 200 ng/L
Maine 130 ng/l 560 ng/l
Massachusetts & Connecticut
70 ng/l Includes sum of 5 PFAS
Michigan 420 ng/L 11 ng/L
Minnesota 35 ng/L 27 ng/L
New Jersey 14 ng/L 13 ng/l
North Carolina 1,000 ng/L ---
Texas 290 ng/L 560 ng/L
Vermont 20 ng/L Includes sum of 5 PFAS
West Virginia 500 ng/L ---
12
C8 Panel Studies ▪ “Probable links” between PFOA exposure and:▪ Diagnosed high cholesterol
▪ Ulcerative colitis
▪ Thyroid disease
▪ Testicular and kidney cancers
▪ Pregnancy-induced hypertension
▪ No correlations with:▪ Birth defects
▪ Miscarriages and stillbirths
▪ Preterm birth and low birth weight
▪ Liver disease
▪ 19 other cancers and 11 other non-cancer effects
http://www.c8sciencepanel.org/prob_link.html
Dupont Washington Works
Wood County, WV
13
Does PFAS cause Cancer?
14
▪ Evidence of PFAS carcinogenicity from C8 Panel studies and animal studies is inconsistent and/or inconclusive
▪ Results of local health studies have been negative or inconsistent▪ Hoosick Falls, NY (2017) – only lung cancer statistically
elevated (lung cancer not otherwise linked to PFAS)▪ Merrimack, NH (2018) – no significantly different cancer
rates, including cancers associated with PFOA▪ Washington and Dakota Counties, MN (2018) – overall cancer
rate same as statewide
▪ Issue is somewhat moot as non-cancer health effects are driving the 70 ppt Lifetime Health Advisory, and this level is protective of potential cancer risk
Risk-Based Standards
Regulatory Authority
Receptor ChemicalReference
Dose (ng/kg-d)
Background Exemption
Exposure Rate
(l/kg-d)
Risk-Based Concentration
(ng/l = ppt)
U.S. EPA LHA
Nursing mother
PFOA + PFOS
20 80% 0.061 70
VT DOHNursing
infantPFOA +
PFOS20 80% 0.175 20
TX CEQSmall child
PFOA 120% 0.041
290
PFOS 23 560
▪ Regulatory authorities are making different assumptions and interpretations in the face of uncertainty
▪ Results thus far: Substantial variability and in some cases adoption of very protective assumptions
Animal
Lab Dose
Equivalent
Human Dose
Reference
Dose
Incremental
Exposure
Drinking
Water Level
LOAEL 200×↓ Metabolism 300 ×↓ Safety 5×↓ Background 4.3 L/day, 70 kg
1,000,000 ng/kg-d 5,000 ng/kg-d 20 ng/kg-d 4 ng/kg-d 70 ng/L
15
PFAS Toxicity Values
16
CompoundU.S. EPA
Reference Dose (ng/kg-d)
ATSDR (draft) Minimum Risk Levels
(ng/kg-d)
PFBS 20,000 ? –
PFHxS – 20
PFOA 20 3
PFOS 20 2
PFNA – 3
Gen-X ? –
Relative Source Contribution also important
PFOA Levels in Blood (µg/L)
17
https://www.dhhs.nh.gov/dphs/pfcs/documents/mvd-pfc-09252017.pdf
▪ Background levels decreased from 5 µg/l in late 1990s to present 2 µg/l▪ Exposure to PFOA in water elevates levels in blood▪ Bioconcentration over time ~100-fold
PFOS Levels in Blood
National average: 4.3 µg/l
Belmont MI individual: 3200 µg/l
PFAS Health Risks - Summary
18
▪ Risk-based standards/guidelines for PFOA and PFOS are likely (possibly highly) protective
▪ Toxicity of PFOA & PFOS not certain▪ Epidemiological studies and laboratory animal studies
have not shown consistent and conclusive findings
▪ Cancer incidence studies in NY, NH, and MN not indicative of PFAS effects
▪ If PFAS is causing health effects, the effects appear to be subtle
▪ Reasons for concern▪ PFAS in drinking water elevates PFAS in blood
▪ Little data for PFAS other than PFOA and PFOS
For More Information …
▪ The Interstate Technology & Regulatory Council (ITRC) PFAS Team
http://itrcweb.org/Team/Public?teamID=78▪ Fact sheets available at: https://pfas-1.itrcweb.org/fact-sheets/
▪ Naming Conventions and Properties▪ History and Use▪ Regulations, Guidance & Advisories▪ Environmental Fate & Transport▪ Site Characterization▪ Remediation▪ AFFF (coming soon)
▪ Detailed technical guidance by 2019
19
20
Contact Information
Thank you for your attention!
Stephen Zemba, Ph.D, P.E.Project [email protected] 802.391.8508
Jeff B. Kray
P re s e n t e r :
Att o r n e y
E - j k r a y @ m a r t e n l a w . c o m D - 2 0 6 . 2 9 2 . 2 6 0 8
S t r a f f o r d C L E W e b i n a r
A u g u s t 7 , 2 0 1 8
Federal and State PFAS Regulatory Developments
22
Regulatory Status - Over v iew
▪ Currently classified as “emerging” contaminants at both the federal and state levels
▪ EPA has established non-binding drinking water health advisories for PFOA and PFOS – 70 parts per trillion
▪ There are no federal and few state numeric standards for cleaning up PFASs in soil and water
▪ At least one PFOA-contaminated site (Hoosick Falls, NY) included on the Superfund National Priorities List
▪ EPA has agreed to publish binding regulatory limits for PFAS in drinking and groundwater this year
▪ Several states have begun statewide testing for PFASs
23
Federa l Regulat ion re : PFAS
▪ Regulation under Safe Drinking Water Act
(SDWA)
▪ Water supply monitoring required for PFOS/PFOA
▪ Health Advisory at 70 ppt
▪ Regulation under Toxic Substances Control
Act (TSCA) and other laws
▪ Manufacturing limits
▪ Not a “hazardous substance”
▪ Regulation under Superfund (CERCLA)
▪ Not a “hazardous substance”
▪ PFAS Summit and EPA’s Next Steps
24
Safe Dr ink ing Water Act
▪ Monitoring required for PFOS/PFOA
▪ 1996 SDWA Amendments require EPA to issue new candidate contaminant list (CCL) every 5 years
▪ CCLs apply to public water systems
▪ PFOS and PFOA added to CCL in May 2012
▪ Drinking water health advisory
▪ Establish May 2016
▪ Set at 70 parts per trillion (ppt)
▪ Non-binding
Title XIV of The Public Health Service Act: Safety of Public Water Systems
(Safe Drinking Water Act)
25
Re g u l at i o n u n d e r Tox i c S u bsta n c e C o nt ro l A c t
▪ Manufacturing limits
▪ 2002 EPA limits manufacturing and importing PFOS
▪ 2007 EPA adds 183 PFASs to limits
▪ PFASs not presently defined as
“hazardous” under:
▪ TSCA
▪ Resource Conservation and Recovery Act (RCRA)
▪ Emergency Planning and Community Right-to-Know Act (EPCRA)
26
Regulat ion under CERCLA
▪ PFASs not presently listed as a
“hazardous substance” under the
Comprehensive Environmental
Response, Compensation, and Liability
Act
▪ But could trigger CERCLA under other provisions:▪ “Substantial danger” to public
health or welfare or the environment
▪ RCRA “hazardous wastes” by characteristics, i.e. “toxicity”
42 U.S.C. §9601 et seq.
27
PFAS Summit and EPA’s Next Steps
▪ PFAS Summit – Spring 2018 EPA Announces Plans for:
▪ Establishing a binding maximum contaminant level (MCL) for PFOS and PFOA “in earnest”
▪ Classifying PFOA and PFOS as “hazardous substances” under CERCLA and developing groundwater cleanup levels “by the fall of this year” to guide the remediation of PFAS-contaminated sites
▪ “Tak[ing] action in close collaboration with our federal and state partners to develop toxicity values for GenX and PFBS,” two other types of PFAS, “by December of this year”
▪ Visiting Michigan, New Hampshire, and other states affected by PFAS contamination to aid in drafting a “national PFAS management plan” “that will be done by the fall of this year”
28
State Regulat ion
▪ Stricter Standards
▪ Vermont
▪ New Hampshire
▪ Michigan
▪ Alaska
▪ New Jersey
▪ Less Strict Standards
▪ California
▪ New York
▪ Washington
29
Str ic ter Standards (VT, NH, MI , AK, NJ )
▪ Established binding cleanup levels for PFOA and PFOS (VT, NH, MI, AK)
▪ Finalizing binding drinking water standards for two PFAS chemicals (NJ)
Image source: 1 Source Occupational Health Solutions
30
Less Str ic t S tandards (CA , NY, WA)
▪ California
▪ PFOA and PFOS are listed on the Proposition 65
▪ Requirement for “clear and reasonable” warning
▪ Washington
▪ Annual reporting requirement for manufacturers under Children’s Safe Products
▪ Restrictions on the sale and use of firefighting foam containing PFOA or PFOS
▪ New York
▪ Restrictions on the sale and use of firefighting foam containing PFOA or PFOS
Image source: National Council for Nonprofits
31
Washington State Developments
▪ PFASs above the EPA health advisory limit have been found
▪ City of Issaquah▪ Joint Base Fort Lewis McChord▪ Naval Air Station (Whidbey Island)▪ Fairchild Air Force Base (Spokane)
▪ New laws passed
▪ ESSB 6143 (PFAS in Firefighting Foam)▪ ESHB 2658 (PFAS in Food Packaging)
▪ Board of Health accepted a petition for rulemaking for PFAS in drinking water
▪ Ecology has begun to develop cleanup levels for PFOA and PFOS
32
Washington State Developments
Chemical Action Plan (CAP) for PFASs
▪ Ensuring drinking water is safe by supporting drinking water limits for PFAS and prioritizing testing for drinking water at higher risk for contamination
▪ Managing environmental PFAS contamination by developing soil and ground water cleanup levels and developing best practices for managing cleanups
▪ Reducing risks to drinking water from firefighting foam by implementing Washington’s new law restricting the use and sale of PFAS-containing foam
▪ Investigating other sources of PFAS that are most likely to pose a risk to human health and the environment, such as industrial releases, textiles, and cosmetics, and support research regarding safe alternatives to PFAS chemicals, particularly in food packaging
33
Current Regulatory L imits
Agency Description PFOS PFOA PFBS PFBA PFNA
EPA Health advisory 0.07 0.07
Canada Drinking water screening values 0.6 0.2 15 30 0.2
ME Maximum exposure guidelines 0.1
MI Drinking water surface water quality value 0.42
NJ Preliminary health-based guidance value 0.44
Health-based MCL 0.013
VT Drinking water health advisory level 0.02
Drinking Water (µg/L)
Agency Description PFOS PFOA PFBS PFBA PFNA
MN Health risk limit 0.3 0.3 7 7
IL Provisional groundwater remediation objectives, Class I
0.2 0.4
Provisional groundwater remediation objectives, Class II
0.2 0.2
NC Interim maximum allowable concentration 1.0
NJ Draft interim specific groundwater criterion 0.02
Groundwater (µg/L)
34
Questions
Jeff Kray
1191 Second Ave, Suite 2200
Seattle, WA 98101
T 206.292.2639
www.martenlaw.com
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Washington | California | Oregon
Overview of Litigation in the U.S.
• EPA’s announcement of health advisory levels for PFOA and PFOS in 2016, improvements in water sampling technology, and public, political, and media attention have resulted in a spike in litigation against the manufacturers of PFAS and some secondary commercial users of PFAS
• Major class action and attorney general lawsuits have been filed involving PFAS manufacturers in Ohio/West Virginia, New York, North Carolina, and Minnesota
• As of July 2018, there is also active and newly-filed PFAS litigation in Alabama, Colorado, Delaware, Florida, Massachusetts, Michigan, New Hampshire, New Jersey, Pennsylvania, Vermont, and Washington
38
Litigation Against Primary PFAS Manufacturers
• Litigation involving PFAS manufacturing locations in Minnesota, West Virginia/Ohio, and North Carolina
• Cases include state attorney general actions, class action claims, and personal injury claims
• Major settlements in Minnesota ($850 million) and West Virginia/Ohio ($670 million)
• Ohio and New York recently brought attorney general suits against PFAS and foam manufacturers
• Michigan also has threatened suit
39
Firefighting Foam Litigation
• Numerous municipal and class action cases have been brought against firefighting foam manufacturers across the United States
• June 2018: New York State Attorney General files suit against foam manufacturers
• AFFF (aqueous film forming foam) contained PFOS, PFOA, and other PFAS chemicals
• Foam sprayed at training sites can persist at sites and enter groundwater and surface water
• Military bases key source of PFAS contamination; several involved in litigation
40
Municipal Litigation• Based on EPA’s Unregulated Contaminant Monitoring Rule (UCMR3) results, an
estimated 6 million municipal water users, supplied by 66 large U.S. water providers, were receiving drinking water above EPA’s 70 ppt health advisory level
• An estimated 16 million additional waters users were drinking water with some level of PFAS
• Smaller municipalities and private well owners also may have drinking water with some level of PFAS (these drinking water supplies were not included in the UCMR3 sampling, but PFAS has been detected in private water supplies in Mich., NH, NY, and VT)
• Municipal water providers are under increasing pressure to provide water to customers with no detectable levels of PFAS
• Some municipalities have been brought into litigation as the result of discharges from waste water treatment plants, firefighting facilities, and landfills
• Several water providers have already brought suit against PFAS and foam manufacturers; more municipal litigation seems likely
41
Litigation Against Secondary Manufacturers
• As many as 90 cases were recently filed against a shoe manufacturer stemming from alleged PFAS releases from a former tannery and landfills in Michigan
• Other defendants in the Michigan litigation include a primary PFAS manufacturer and private landfill owner/operator
• CERCLA 106 order from EPA, RCRA lawsuit filed by Michigan Department of Environmental Quality (MDEQ), Class Action litigation
• Litigation against carpet manufacturers in Georgia/Alabama
• Litigation against circuit board manufacturer in Hoosick Falls, New York includes class and municipal claims
• EPA proposed adding Hoosick Falls Site to Superfund list in September 2016
42
Emerging Contaminants; Emerging Diligence Issue
• Shifting regulatory landscape with differing state standards and emerging federal standards
• Diligence should consider PFAS chemicals currently subject to regulation and those likely to be subject to additional regulation in the near future (ex. GenX)
• A broad definition of PFAS in sales and purchase agreements and/or indemnification agreements may be beneficial to buyers/sellers
• Environmental insurance may help protect parties
43
Potential Diligence Red Flags for Buyers Acquiring Operations
• Manufactured PFAS chemicals or firefighting foam
• Supplied products containing PFAS to third party manufacturer
• Processed, manufactured, or used (in large quantities) oil or water resistant or repellant fabrics, furniture, carpets, waxes, adhesives, or other products containing PFAS
• Disposed of large volumes of consumer or industrial products containing PFAS; disposed of construction and demolition waste; involved in bio-solid or paper composting operations
44
Diligence in Real Estate Transactions
• Fire training/suppression or firefighting facility on or near the property
• Industrial fire or major accident on or near property• Manufacturer located on or near the property that
processed or treated product to make it water or oil resistant (or used Scotchgard or similar materials in large volumes)
• Located near a landfill, airport, or military base• Fill or composting material containing PFAS used at the
site• Known PFAS contamination onsite and located near
municipal or private drinking water sources or surface water
45
Additional Diligence Considerations
• Persistence: PFAS are durable in the environment and may be discovered decades after their release or disposal
• Pervasiveness: PFAS are mobile and can spread across the environment; there are several potential exposure routes (including airborne deposition, groundwater, and surface water)
• Narrow manufacturing base in the U.S.: A small group of companies manufactured nearly all of the PFAS in the United States, but many companies used PFAS in their products
• Overseas PFAS manufacturers and exporters: A large number of consumer products imported into the U.S. contained PFAS prior to regulation under TSCA
• Jurisdiction: state standards are likely to be different with some states adopting much stricter PFAS sampling and cleanup standards (exs. Vermont, N.H., Mass., and N.J.)
46
PFAS Occurrence and Treatment OverviewRussell Abell, PG, LSP
Sanborn Head & Associates, Inc.
August 2018 Stafford CLE Webinar - PFAS
48
PFAS in Public Drinking WaterU.S. EPA 2013−2015 Unregulated Contaminant Monitoring Rule Sampling
Hu et al., ES&T Letters, August 2016, http://pubs.acs.org/doi/abs/10.1021/acs.estlett.6b00260
▪ Areas indicated watersheds
▪ Large water supplies (> 10,000 people)
▪ Estimated 6,000,000 people > EPA Health Advisory
PFAS Occurrence in Drinking Water Wells
49
Study/Site PFOA DF (# detects) > 70 ng/L
PFOS DF (# detects) > 70 ng/L
SamplePopulation
Sample Type
UCMR3 0.3% (13) 0.9% (46) 4,920 Public water systems
NH Domestic Wells
12.1% (214) 0.7% (12) 1,762 Domestic Wells
Study/Site PFOA DF (# detects) > 400 ng/L
PFOS DF (# detects) > 200 ng/L
Sample Population
Sample Type
UCMR3 0% (0) 0.4% (19) 4,920 Public Water Systems
NH Domestic Wells
0.9% (16) 0.1% (2) 1,762 Domestic Wells
PFAS in Landfill LeachateLang et al., Lang J, Allred B, Field J, Levis J, Barlaz M (2017). National Estimate ofPer‐ and Polyfluoroalkyl Substance (PFAS) Release to U.S. MunicipalLandfill Leachate. Environ Sci Technol 51(4):2197‐2205.
0
500
1,000
1,500
2,000
2,500
3,000
3,500
4,000
B E F G H I J K L M N O P Q R S T U
Co
nce
ntr
ati
on
(p
pt)
Landfill Identification
PFOA+PFOS
70 ppt
50
Groundwater Concerns at Landfills – Data from NH
DF > LHA/AGQS is 0.30 for PFOA/PFOS
Median is less than 50% of LHA/AGQS for PFOA/PFOS
PFAS Detection Frequency at NH Landfills
Concentration Bins (ng/L) PFOA PFOS PFBA PFPEA PFHPA
ND - 69 0.67 0.67 0.63 0.70 0.72
70 - 99 0.07 0.10 0.07 0.00 0.14
100 - 999 0.23 0.20 0.30 0.30 0.14
>1,000 0.03 0.03 0.00 0.00 0.00
51
Concentrations (ng/L)
PFOA PFOS PFBA PFPEA PFHPA
Min 0.50 0.44 0.55 1.0 0.89
Max 2200 1560 493 260 410
Mean 12.9 18.0 13.7 14.0 8.0
Median 9.0 17.1 21.7 18.5 10.8
PFAS Detection at NH
Landfils
PFAS Remediation/Treatment Options▪ Current ex-situ treatment
▪ GAC
▪ Ionic exchange with resins
▪ Reverse osmosis
▪ Nano-filtration
▪ Potential for in-situ methods
▪ PRBs using sorptive media
▪ Phytoremediation
▪ Experimental approaches
▪ In-situ oxidation –only effective for PFOA
52
PFAS Water Treatment Challenges▪ All are costly
▪ Reverse Osmosis
▪ High concentration residual
▪ Sorption - GAC
▪ Early breakthrough for short chain PFAS
▪ Potential pre-treatment Issues
▪ Ionic Exchange –Resins
▪ Not all resins are the same 53
From Hagelin N. and Woodard S, Sustainable
Removal of Poly – Perfluorinated Alkyl Substances
(PFAS) from Groundwater Using Synthetic Media
Measuring Progress – QC Concerns▪ GW methods still
nascent
▪ High variability, low precision
▪ Still no standard method for soil
▪ 2-5 regulated compounds - others
▪ Potential cross-contamination concerns
54