A per- and polyfluoroalkyl substances (PFAS) investigation is headed for a site near you… State and federal regulators are increasingly issuing PFAS investigation orders and requiring the addition of PFAS to site characterization plans. Further, some parties are opting to conduct voluntary PFAS site investigations as a means of managing future risk and liability. PFAS investigations can be daunting given the heightened scrutiny required of sampling procedures, the state-by-state patchwork of ever-lower regulatory criteria and the financial and legal implications potentially associated with investigation results.
Site investigations are used to answer fundamental questions such as: What is the extent of the contaminant footprint? Is the contamination migrating off-site? What is the source of contamination? Do contaminant levels exceed regulatory criteria? While PFAS site investigations generally follow the same principals as those for other environmental contaminants, they also pose unique challenges and require PFAS-specific considerations stemming from the ubiquity of PFAS and the evolving state of the scientific, regulatory, and legal landscape. Taking these considerations into account is a step towards achieving a PFAS investigation that produces accurate, defensible data and meets the investigation’s overall objectives.
by Ned Witte is a shareholder in the Environmental Strategies Practice Group.