…the Status of Environmental Cleanup

October 2018

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We were cleaning everything up to non-detectable levels

Then came risk-based corrective action; the fundamental premise being that concentrations don’t matter so long as there is no exposure

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We’ve found ourselves chasing vapors in both a subsurface & ambient environment, where the leading edge of a plume may far exceed the extent of soil or groundwater impact we had previously delineated

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We’re on to per- & polyfluoroalkyl substances or PFAS

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A group of emerging & potentially harmful contaminants used in thousands of applications globally, from fire-fighting foams, stain repellants, nonstick cookware, waterproof clothing, food wrappers & even cosmetics

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They don’t break down readily in the environment, can bioaccumulate over time (in plants & animals) & move easily into water

Exposure to PFAS has been linked in human studies to certain cancers, kidney disease, thyroid conditions & auto-immune disorders

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2002-2008: 3M voluntarily phased out production

2010-2015: 8 other manufacturers eliminated production

Production shifted to Asia & Eastern Europe Exemptions: EPA allows continued, low-

volume use in specific applications (semiconductor, etching, metal plating, aviation & photographic/imaging)

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In January, the Michigan Department of Environmental Quality (MDEQ) set a new legally enforceable standard of 70 parts per trillion for certain PFAS compounds, such as perfluorooctanoic acid (PFOA) & perfluorooctanesulfonic acid (PFOS), something only a handful of states have done thus far.

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The criterion is set at the lifetime health advisory level (HAL) published by EPA in 2016, under which compliance requires comparing the sum of the PFOA & PFOS concentrations to the drinking water criterion of 0.07ug/L.

(HALs don’t establish a regulatory limit or “maximum contaminant level” [MCL]. They provide guidance to state & local officials in evaluating drinking water quality based on levels below which adverse health effects are not anticipated to occur over a lifetime of exposure.)

With this criterion, MDEQ can now issue violation notices & act against any responsible party who doesn’t comply with the state’s cleanup rules.

A part per trillion is one droplet of water in an Olympic-sized swimming pool. So 70 parts per trillion would be about 70 droplets (BTW - an Olympic pool holds about 660,000 gallons of water!)

1.5 drops out of the average consumption of water in a lifetime

About 0.18 seconds in an American woman’s average lifetime of 78 years

7 cents out of $1 billion

Less than 1 person out of the world’s population

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In fact, it is. The amount -- even at microscopic levels -- can still matter because of the way cells interact with molecules. Our cells respond to those levels, even at a part-per-trillion concentration.

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PFAS contamination has been found in more than 30 locations in 15 different communities across the state, including several military facilities, like Wordsmith Air Force base.

To underscore its significance, last fall Governor Snyder created the Michigan PFAS Action Response Team (MPART) to address this emerging issue & help inform the public.

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MPART is currently midway through a $23 million state-funded effort to locate PFAS contamination, identify sources & oversee remediation activities aimed at protecting the state’s water resources & mitigating risks to the public.

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In May, MDEQ began sending letters to Michigan’s 1,380 public water systems, outlining its plans to conduct a state-wide PFAS study of public water supplies.

In addition, 461 schools that operate their own wells are being considered priority testing sites under the initiative.

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A state of emergency has been issued for Kalamazoo County because of the ongoing health & safety concerns due to PFAS contamination in the drinking water for Parchment & Cooper Township.

PFAS has been found in fish, foam & water samples near the Camp Grayling Army Airfield & Lake Margrethe area in Crawford County.

PFAS has been found in foam & water samples near House Street in Belmont from a Wolverine Worldwide, Inc., disposal site in Kent County.

PFAS has been found in fish & groundwater samples near the Former Wurtsmith Air Force Base in Iosco County.

PFAS has been found in groundwater samples near the Alpena Combat Readiness Center in Alpena County.

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MPART’s efforts have led to the development of several methods to measure & track contamination in groundwater.

Sampling protocols are stringent & arduous – no waterproof note pads or clothing, no Teflon tubing or connectors, no plastic clipboards, no Scotch Guard or Gortex & no cosmetics.

The applicability of many cleanup technologies is limited because remediating PFAS contamination has only recently been contemplated.

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Excavation & offsite disposal Pump & treat

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Adsorption Bioremediation Chemical oxidation Chemical reduction Electrochemical oxidation Incineration & thermal treatment Membrane filtration Solidification/stabilization Sonochemical treatment

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In May, EPA announced it will visit several communities impacted by PFAS to understand & support work being done at the state, local & tribal levels.

EPA also announced it plans to develop a PFAS management plan to be released later this year.

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EPA has started the process of designating PFOA & PFOS as “hazardous substances” through available statutory mechanisms, including potentially CERCLA section 102.

EPA is developing groundwater cleanup recommendations for PFOA & PFOS at contaminated sites & will complete this task by fall of this year.

EPA is collaborating with federal & state partners to develop toxicity values for GenX & perfluorobutane sulfonate by this summer.

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PFOA & PFOS are made up of “chains” of eight carbon atoms attached to fluorine & other atoms.

Replacement chemicals, like GenX, tend to have fewer carbon atoms in the chain, but have many similar physical & chemical properties as their predecessors (e.g. they both repel oil & water).

U.S. industries have phased out production of PFOA & PFOS because of concerns about health risks to humans & have been using replacement PFAS, such as GenX.

There is a substantial body of knowledge for managing risk from PFOS & PFOA, but much less knowledge about the replacement PFAS.

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Acceptable PFAS exposure levels continue to be debated nationally. (Many researchers argue the 70 ppt safety threshold should be lower!)

A June report by the Agency for Toxic Substances & Disease Registry found the current health advisory could be 7-10 times higher than levels that would pose a minimal risk.

EPA is initiating steps to evaluate the need for a maximum contaminant level (MCL) for PFOA & PFOS.

Michigan Governor Snyder said more information on whether his state should lower its health advisory would be coming in a few months.

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In July, ABC News reported all 28 groundwater wells tested at Patrick Air Force Base, near Satellite Beach, showed potentially harmful levels of PFOS & PFOA, ranging from 71 parts per trillion -- just slightly over the EPA’s acceptable limit –- to as high as 4.3 million parts per trillion.

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Approximately 250 public drinking water systems (PWSs) statewide were sampled between 2013 & 2015.

PFAS compounds were reportedly detected in 12 PWSs, but only 3 were reported at levels exceeding EPA’s established HALs.

Further evaluation and/or corrective actions have been taken or are ongoing. Examples: In Stuart, the water, which is pumped to 19,000 customers, tested positive for PFOS & PFOA in 2014 & 2015, the first years EPA tested for them. In 2016, when EPA recognized the dangers, the city closed & later replaced the wells contaminating the water supply. Stuart's highest level was 180 in 2014. It reportedly averaged 43 in May 2017. On August 2, 2016, Zephyrhills reported results of 20 parts per trillion for PFOA & 120 parts per trillion for PFOS; a combined value of 140 parts per trillion. The affected well was removed from service.

FDEP & DOH have partnered to sample approximately 100 private drinking water wells. This sampling began in fall 2016 & is ongoing. Results of this sampling will be used by DEP & DOH to determine if any further testing is needed.

In June 2018 & at the request of FDEP, the UF Center for Environment & Human Toxicology calculated irrigation water screening levels (IWSLs) for PFOA and PFOS it believes are protective of human health under an irrigation scenario.

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Experts are becoming increasingly concerned by the potential effects of high concentrations of PFAS on human health.

Although there is more to learn about PFAS & human health, states like Michigan are taking this issue very seriously.

The MPART discoveries & issues like those at Satellite Beach suggest other states might not be far behind when it comes to establishing limits on PFAS in drinking water.

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… we were cleaning everything up to non-detectable levels … (don’t blink).

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Marc D. Florian, CPG, RG, CUSTP Vice President | Site Assessment & Remediation Group 269-927-3366 (Office) | 268-927-3684 (Fax) mflorian@ectinc.com | www.ectinc.com