Insurance to Manage Remediation Costs and Risks

Dane: Hello and welcome everyone. My name is Dane Menke. I am the digital marketing manager here at REGENESIS and Land Science. Before we get started, I have just a few administrative items to cover. Since we’re trying to keep this under an hour, today’s presentation will be conducted with audience audio settings on mute. This will minimize unwanted background noise from the large number of participants joining us today. If the webinar or audio quality degrades, please try refreshing your browser. If that does not fix the issue, please go ahead and disconnect and repeat the original login steps to rejoin the webcast. If you have a question, we encourage you to ask it using the question feature on the webinar panel. We’ll collect your questions and do our best to answer them at the end of the presentation. If we don’t address your question within the time permitting, we’ll make an effort to follow up with you after the webinar. We are recording this webinar, and a link to the recording will be emailed to you once it is available. In order to continue to sponsor events that are of value and worthy of your time, we will be sending out a brief survey following the webinar to get your feedback.

Today’s presentation will take a look at where PFAS regulation started and where they may be headed globally, including in the United States. With that, I’d like to introduce our presenters for today. We’re pleased to have with us Dr. Rosa Gwinn, Global PFAS technical lead with AECOM. With 30 years’ experience with AECOM and legacy companies, Dr. Gwinn’s primary focus has been on the characterization and remediation of emerging environmental contaminants including PFAS, chlorinated solvents, explosives, and metals. Stemming from a career focused on innovation around emerging environmental challenges, she leads AECOM’s Global PFAS technical practice. With a foundation in solving difficult remediation issues, she had recognized the need to focus AECOM’s creative strength on addressing PFAS and drinking water, wastewater, and the environment. Central to this role is interfacing with clients, academic partners, trade associations and government agencies, and anticipating and influencing PFAS regulations.

We’re also pleased to have with us today, Scott Wilson, president and CEO of REGENESIS. Scott Wilson has extensive experience in the development and application of advanced technologies for groundwater and soil restoration. He is a widely published expert, with over 30 years’ experience designing, installing, and operating a broad range of remediation technologies. He has expertise in project management and has directed the successful completion of large industrial remediation programs under state and federal regulatory frameworks. At REGENESIS on specific projects, he plays an active role, a technical oversight, and program management to ensure conformance with customer expectations. All right. That concludes our introduction. So, now I will hand things over to Rosa Gwinn to get us started.

Dr. Gwinn: Thank you. It’s really nice to be here and be able to talk a little bit about the state of play and PFAS regulations. I’m gonna talk a little bit about where things are globally and in the United States and maybe have a chance to look ahead down the road a little bit. I’m not gonna spend any time talking about PFAS basics. I think everybody on this group probably knows those. So, I’m just gonna assume some state of knowledge is already in play for you folks. All right. Well, let’s get started. So, I did feel obliged to define PFAS up in the upper left corner there. And I am gonna talk about these three topics, the global regulatory status, U.S. regs, and then I’m gonna get out my crystal ball and have a look, see what the future might be bringing with, of course, caveats, but it’s hard to tell the future. When I was talking to our friends at REGENESIS about this presentation, we were sort of joking about the 2020 means, how it started, and how it’s going, and sort of hoping that with PFAS the images are reversed. And we started kind of frazzled, but at the end, we’ll all be in line and be as lovely as the Monalisa is.

So, just with a little minimal background here, of course, PFAS were discovered in the 1930s and became important for some research applications early on in the United States, and then later entered into the consumer industry or industrial applications certainly and with the advent of Aqueous Film Forming Foam or AFFF which contains PFAS’s active ingredients, there was an introduction of a way to really quickly and effectively fight liquid pool fires. So, there were some great advantages when these fluorinated compounds were introduced. And then society embraced some of the enhancements that the non-sticky, non-staining repellent materials could offer and developed household goods and industrial goods that contained PFAS-related compounds, some of which are very well known to most people, Teflon, of course. But some of which are occurring in places that you might not actually expect them. And we’re learning more about that over time.

All right. In the ’80s, there started to be some scrutiny on manufacturers of the Teflon-related products and a concern about potential discharges of those materials and overall burgeoning of the environmental movement, if you will. People were somewhat more focused in the 2000s on identification as what they call a global distribution of PFAS. And we’ll see that they are appearing in a lot of different countries. And what maybe was quite alarming was, of course, the polar bears is sort of a key example. But they were occurring in biota that had no relationship to these industrialized remanufactured products. So, there was a recognition that there was something going on in our ecosystems that was allowing these persistent bio-accumulative and toxic chemicals to appear in life forms where they shouldn’t be. And there’s some other notable examples from the 2000s. And the studies are manifold, including things like dragonflies in South Africa, for example.

Now, the current state of play, I’m trying to get at it with this graphics that HDSDR developed is that…I think our understanding of PFAS has become more nuanced and we’re understanding that not only are there different kinds of chemistries, just like an organic chemistry, you know, milk and propane are both organic chemicals, but we’ve never clumped them together and say they’re the same. So, it is with PFAS. And there’s a recognition that we have the alkyl acids and we have polymers and non-polymers, actually, is really the point I was trying to make. So let’s just keep that in mind going forward, and it should be part of our crystal ball calibration. Okay. I’m gonna move along and talk a little bit about the global regulatory status, a big topic. I’m sure I won’t be able to encompass all of the nuances, but I’m hoping that by sharing some of the information about how countries across the globe are managing PFAS in a regulatory fashion, we can learn a little bit more about how we might wish to be thinking about PFAS.

I put together this graphic. I simply looked for the geography that were of interest to me and tried to determine if there was some nationwide information about PFAS-containing sites. And indeed, I could have probably peppered this map with a lot more locations. I could probably have done a better job showing all of the United States and not just the continental United States. But as it stands, my intention is to share with you that there is certainly an indication that across the globe, there are communities, federal communities, national communities that are focusing on where they believe PFAS may be present in the environment, in drinking water, in other media, in animals, on surface water, you name it. And many efforts have gone underway in order to make those measurements. And only a few of them are depicted here. So, what’s your takeaway? Well, certainly one of my takeaways is you’ll often hear, oh, PFAS are everywhere. And I often rebut that by saying, well, they’re not everywhere. They’re just in a lot of places they shouldn’t be. But heck, if you look at some of these maps, they’re in a lot of places. And notwithstanding that these don’t really demonstrate concentration or severity in issues. I hope you get the impression that this is, in fact, a global concern.

And I’m gonna make one last comment about the U.S. map because I think there’s some information that can be misleading. I’ve elected to use this map because it’s often seen in other people’s presentations, but also a very handy location where the group is compiling information on a regular basis. But when you look at the U.S. map and you think to yourself, “Heck, there’s some states I really don’t wanna live in. They seem to have a lot of PFAS problems.” And you need to remind yourself that that is an artifact of where it’s been measured, where PFAS has been measured in drinking water or other media, and so, therefore, the density of the locations on that map for the U.S., in particular, are bias.

Okay. So, what does that mean that they’re everywhere? We certainly don’t have a global governing body. And what we do have is a global concern about how we’re gonna manage this if we indeed intend to manage it as a society or individually by country. So, what I’ve presented here is also biased, right? And it’s biased because identifying the currency value of the global PFAS liability, it’s actually pretty tricky. And these just happened to be three geographies for which there were published information, estimating what the PFAS environmental liability was. So, this excludes litigation or health concerns. And it also excludes replacement of the AFFF that I mentioned earlier with alternatives and cleaning up the infrastructure associated with that former AFFF use. But I think you can get one picture as a takeaway, and that is the U.S. is probably has a lion’s share of some concerns for cleanup. But the country regardless of size or areas of the globe are also going to be visited by these concerns. The other takeaway is, you know, the U.S., I think, justifiably has been moving in a rather cautious fashion. And if you look at the literature, Australia or clumpiness Australia, New Zealand, and the Nordic countries have actually been moving a little bit more quickly on looking at management alternatives and source remediation. So, we can often take a lesson from our friends in other countries about where the U.S. is going.

There’s an overall maybe human characteristic that there’s an ebb and flow of interest. And so it is with international PFAS regulations. So, you might have an event, an observation, or detection of PFAS and drinking water, for example, in Ohio, West Virginia in the early 2000s or a large fire that was fought in the UK and unseal the terminal site, or the identification of PFAS in rivers in Arnsberg and Moehne in Germany. And that created an interest. So, there was an activity… There was international regulatory activity that then kind of ebbed as the next concern came up. And in the EU, there was early action on food safety. EFSA is the EU Food Safety Authority. And then, you know, additional identification of sites that were associated with Australia defense and Oakey and Williamtown were concerned. And the UCMR 3 data collection in the United States was a concern. It created more concern. So, without belaboring the point, I think what we can convince ourselves is that there are a variety of factors that drive regulations and influence them to be more or less aggressive.

This graphic is intended to show at a glance really where the regulatory activity is occurring. And you can see why I biased my earlier map related to that. And there are PFAS criteria in the countries that are highlighted in blue. And in the United States, there’s a bit of a patchwork quilt. And we’re gonna spend a little bit more time talking about each of these geographies in a little more detail especially with the United States. Okay. So, hang on to your heads because I know this is an eye chart and it’s really just probably way too much information. So, why the heck did we put it all together? Well, it was a valuable way to get some takeaways. And I’m gonna try to give you the cliff-notes version of what’s going on here. So, if you look at the regulatory action on the left-hand side, there’s a focus on manufacturing and importation. Right? And how did these geographies, the U.S., Australia, and EU do it? Well, they used existing regulations where they identified alternatives. And there was definitely a change in the manufacturing scheme of PFAS. But there’s also an effort to continue to inventory them.

What is driving the regulations differs based on the geography. And the U.S. is just fundamentally pretty process-driven. Everybody has heard about the risk-based approach that we need to follow CERCLA. There is quite a bit of attention on food consumption. And there is also attention in the U.S. and Australia on having an overall plan. And most folks on the phone are probably familiar with the PFAS action plan that the EPA released in 2019. So, then we’ll start talking about some standards. And I’ve got a lot of cats and dogs in here such as, again, you know, pay attention to a couple of high points. If you look across the exposure-based standards, what is represented in the top row of information or standards for consumption exposure or a tolerable daily intake of PFOS and PFOA in the U.S. through the ATSDR or this EFSA in Europe that I mentioned earlier. And I’m just gonna focus really quickly on the left column on the right because this EFSA release in 2020 is pretty notable. We’ll see that they have what they call a tolerable weekly intake. And it’s reported in nanograms per kilogram of body weight, in this case, per week. And they’ve identified 4.4 nanograms per kilogram body weight per week, which is just a remarkably low number. We hardly ever talk about such low numbers, but so it is with PFAS. And the most remarkable thing is that’s actually dropped from the prior EFSA directive, which is also shown in that column there.

So, I think you see where things are going on the numerical values. And we’re all pretty aware of this. I’ve also mentioned the drinking water values just for your reference. But here we are now we have to look at all the PFAS, right? And if you look in the U.S. EPA comprehensive toxicology data set, it lists now over 9000 chemicals that have this carbon-fluorine moiety. That’s overwhelming. And we’re never gonna get there if we have to think about things collectively. But we’re also never gonna get there if we don’t separate the wheat from the chaff, meaning what are the most important compounds to regulate and which ones are less important? And as a consequence, Australia has adopted a toxicity equivalent quotient which is gonna be a very helpful shorthand way to get where you need to be. I’m gonna remind people of how we worked with polycyclic aromatic hydrocarbons in the past when we evaluated risk and we used some with known toxicity as it go by.

Okay. So, I have to move on here or else we’re never gonna get where we need to be, which is the crystal ball. One thing is that the number of PFAS compounds garnering attention increases over time. And I’ve borrowed this graphic from the ITRC document. And the intention is to just help you focus that we were talking about PFOS and PFOA back in the day. And if you look across the chart, you see the two top two rows, that’s largely what different geographies have been creating standards for. And this is sort of any kind of standard is collected here. But you’ll also see as we go down that chart that you’re starting to see more complex groups of compounds being regulated. And when we talk about thousands of compounds, we have to just embark on with a little bit of care. Okay? But the number of different geographies that are looking at PFNA and PFHxS should be an indicator to us that, you know, there’s a sense of greater knowledge about those two in particular. But it’s not just the number of compounds. It’s also the concentration. And the left-hand side is a compilation of drinking water criteria, again, by geography, and it’s mixing states and countries.

And what you generally see is you have a risk level that is kind of imbalance where a lot of things show up that’s 270 parts per trillion. Note that that’s a logarithmic scale on the left. But that’s not the notification level. And in California, the notification levels are much lower. So, what about the soil? So, what are people doing about soil exposure? And on the right-hand side you see soil residential standards, so that’s for direct residential exposure. And those numbers aren’t protective of groundwater. So, if you wanna protect your drinking water to the numbers that are on the left-hand side of the chart, you’re gonna have to create some soil standards that are significantly lower than the numbers that you see on the right-hand side of the chart. So, I think we can say, with confidence, that’s where the soil numbers might be heading. And how we’re gonna get there is the complex part.

So, let’s move on to U.S. regulations. I think most people have a flavor for what’s going on in the U.S. And this is, again, sort of a dual snapshot where we were and where we’re going, right? In 2015, there were very few states with guidance. And you can see highlighted just a handful and the reasoning behind those guidelines. It’s a little hard to see, I just wanna make the point on the 2015 charts in Hawaii is shaded in gray. So, it does not have a standard. And then at the current state of play is shown on the right-hand side. I don’t show the states that have adopted the 70 petroleum federal guideline health advisory. But you can see that there’s a petrol quote erupting here. And we’re gonna be met with a situation where water flowing from Michigan to Indiana is gonna be subject to different considerations. And that’s something we’re gonna have to, as a community of consultants, we’re gonna have to manage. Right?

So, let’s see. I think the states are driving the regulations in the United States. And I think that we also have to grapple with the fact that states are somewhat all over the map. This is just a recreation of that last map you saw, but with a few additional points to be made. Nineteen states have water criteria. Six states have drinking water limits that are different from the U.S. EPA advisories which are shown on the right-hand side, and so on and so forth. I mean, Texas is managing 16 different PFAS compounds. And in California, I mentioned earlier, the notification levels have really just gone very low. So, you have to be on alert earlier, then when things might hit a federal criterion. And I might wanna add here that the federal screening level for CERCLA-based activities has been set at 40 parts per trillion. So, what’s this chart, Rosa? The PFAS state water regulations. It’s what I was just talking about on the previous map, but showing you those regulations over time. And of course, each state has adopted its regulatory criterion on its own timescale. And when you take a look at this, you’ll see on the left-hand side, the EPA first out of the block, and it had higher standards higher than the chart is showing. And then later adopted the 70. But as you look from left to right, it’s not really that important which state you’re looking at. But if you generally test your eyeball from left to right, I think you’ll agree with me that there’s an overall downward trend in these concentrations that are being regulated. And as a consequence, I think, you know, we need to ask ourselves, “Is there a race to zero? And what does it really mean? Is it being driven by risk-related questions or is it being driven by our ability to make measurements?” And those are two very different things and they have different implications for how regulations might unfold.

So, I sent you a lot of kind of unusual information, hopscotching the globe and looking at different states. And maybe not all of the news was altogether that good. So, I felt obliged to share some good news, it’s also kind of personal news. I think a lot of people are familiar with this statement that the CDC has performed some statistical measurements and monitoring as PFOS in blood serum in humans. And they’ve done it over a long period of time. Just recently, under the National Health and Nutrition Examination Survey, they released the new data. So, in the beginning, they only measured a few PFOS compounds and the detection limits were probably pretty high. And some have gone, you know, 99% of the United States has some form of PFOS in their blood serum and that seems pretty sad. But if you look over time, those concentrations are reducing. And it’s, you know, a dual relationship between some excretion, of course, from the human body. The overall benefits of having reduced manufacturing of PFOS and therefore released into the environment. And then, of course, the changing of the population. Younger people haven’t been exposed to prepare so long as I have.

So, I think it’s pretty good news. We have the benefit of seeing that…and then this is on average. You can go look at the data. It’s broken out by different demographic characteristics. But I think overall, a takeaway is maybe it’s a good thing what we did. So, here’s the crystal ball portion. And I am gonna hit you, again, with a couple more eye charts. So, hang on to your hats, cats. So, where do we think standards are gonna go? Australia, I’m gonna start in the middle, is definitely focused on risk-derived soil criteria and with the protection of drinking water, right? Europe, they continue to update standards. And there are several at play depending on how the community of EU nations wants to collectively manage PFOS and surface water, in particular. Those are underway and countries are going to be evaluating those standards in the EU. In the U.S., I mean, it’s no mystery that an MCO is on the docket likely just for PFOS and PFOA. And it seems like it will take just for the process to unfold 18 months. So, it’s hard to see how that can go faster because of the public comment period. But what can go faster is the hazardous substance designation for some PFAS. Again, this conundrum of having so many compounds. And I think that might move a lot more quickly because it can happen through a different regulatory mechanism. And I think that there’s going to be a lot more information about toxicology, the EPA is gathering information on many, many PFAS and we may have more characters to manage.

Soil management is a big deal because we have construction projects ongoing that folks have to be cognizant of managing PFAS and soil and groundwater at those construction sites. And I think you can see for yourself that one of the other issues with soil management is gonna have to be disposal. And disposal options are gonna be driven by technology. I’ll make a note about that a little bit later that the EPA is guidance. The EPA has said, “Well, here’s some three great ways to…three acceptable ways to dispose of PFAS-related waste, landfill, incineration and deep well injection.” And the technology isn’t commercial elsewhere on others. So, we have a situation where we’ve got to manage our problem. And I think we’ve got the right audience today for talking about that. And there’s gonna be a longer-term attention on disruptive technologies clearly. And unless you’ve been living under a rock, you probably have heard about biosolids reuse and groundwater reuse as issues that people are focusing on because of the potential to recycle PFAS and the ecosystem and the environmental system from our drinking water problems and so forth. Right?

So, then we get to surface water. In the EU… Actually, UK has some surface water limits that they are identifying, but the EU, not quite yet. More focused on food packaging. The Australia and the U.S. are focusing increasingly on ecological standards and accumulation factors that are associated with the eco-criteria and web food modeling. It’s gonna happen. There has to be some interim protections for us on the pathway and sources just to buy time for the science and engineering to catch up. And then I’ve listed here a handful of research programs across these geographies that are helping fund changes and what we know and understand about PFAS treatment and handling.

Okay. So, what are your takeaways? There’s certainly differences in standards, but overall, regulations seem to be very driven by probably what it should be, and that’s the priority of protecting the community. Typically, each geography has restricted use, manufacturing, and discharge. They have taken steps of inventory like the UCMR 3 and developing action plans. That seems to be common. The pace of action just seems to be related to the context of what’s going on in that geography and what the magnitude of the problem is by region, including by state. It looks like PFAS concerns are certainly healthy, and focused, and commercial use of food packaging. PFAS in food packaging and, of course, the appearance of PFAS in biosolids. I mentioned we need to expect the Federal MCL, that hazardous waste designation is a super game-changer. And the state standards are just gonna keep on moving. And they may be going down to zero as I kind of jokingly said earlier. And I think we have to worry about other kinds of PFAS compounds. And finally, destructive technologies. The EPA didn’t mince any words. They’re still looking at that and because of the limitations of other disposal options. So, I’m gonna end there. I know it was a lot of information packaged in sort of a tight space there. I would encourage you to feel free to reach out to me if you wish. But now I think it’s more important that I turn the floor over to Scott Wilson from REGENESIS because he certainly has some information to share about what you can do now to manage your tricky PFAS issues. Scott?

Scott: Well, Rosa, thank you very much. That was great. And it’s a real pleasure to have a true global PFAS expert from AECOM joining us to share your knowledge. It was very, very, very concise and great. So, I’m here to… I’d like to just take a moment to talk about PlumeStop, and how PlumeStop injections can eliminate the risk of PFAS and groundwater in situ. And at the end, I also wanna bring up a new commercial program we have where REGENESIS is taking on the financial risk of cleaning up some of these PFAS sites. So, let’s dive right in and talk about PlumeStop. And if you’re not familiar with PlumeStop, what we’ve done is we’ve taken activated carbon and we’ve milled it to the size of a red blood cell, one to two microns in size, and suspended it in water with certain polymers so that you get a suspension that looks about like fountain pen ink. And it’s an actual true colloid in that it doesn’t settle out. And you can actually take this material and pour it into wells and it’ll move out into the aquifer under low pressure without any injection and without any fracturing. And it will distribute in the aquifer. And it will coat the aquifer matrix with a layer of carbon. Now, you can inject it if you want under pressure, but it’s not required. And it will actually permanently coat the subsurface aquifer matrix producing a purifying filter. And I’ll also get to it a little later, but it’s very cost-effective in that a single application will last decades pulling the PFAS out of suspension and eliminating the risk downgradient.

So, how does it work and what’s it look like? So, here’s an electron micrograph of an actual sand from an aquifer. This is a sandy aquifer. And you’re looking at… If you look at the scale at the bottom, that’s 50 microns across. So, that’s what it looks like. You then flow PlumeStop through. And what you’ve done is you permanently coated the sides of those sand grains and you’ve made a purifying filter. And now we’re looking in a little bit closer here. There’s a 20-micron scale on that, so it’s a little bit closer. So, you can see the carbon. But again, you just flow it into the aquifer and in the zones that are carrying the water with the PFAS. Those zones or the matrix actually gets coated with this carbon producing a permanent purifying filter.

So, as I mentioned, the activated carbon and PlumeStop, it coats the matrix permanently and it provides extremely fast sorption. So, we’ve all heard of using activated carbon in canisters above ground in pumping and treating systems. This is very different in that the carbon itself is finely milled offering much greater exposure to the sorption sites because of the, what we call the outward-facing or aqueous-facing surface area of the particles. Work done at Colorado School of Mines, for example, has shown, you know, orders of magnitude, greater kinetics, and sorption of PFAS by just, you know, a threefold, fourfold, fivefold reduction in particle size. Here you have an order of magnitude reduction of particle size. So, you get much, much faster sorption kinetics. The result is that you actually permanently coat the zone in the subsurface of the aquifer and be converted into a purifying filter. And as the plume migrates through that zone, the contaminants are sorbed out of solution. And the water is free to migrate but it just sorbs the contaminants out of solution.

So, here’s a cartoon, if you will. And let me just sort of set you up here. What we have is we have these red zones. They represent zones of higher permeability. And you have water moving from the left to the right of the screen. And PFAS is denoted by a red color and it’s moving through the high flux zones, those zones that are taking high flow rates of groundwater. And as the groundwater flows from left to right, the PFAS is moving through. Well, it starts to diffuse into the lower permeable zones, that’s forward diffusion. So, you’re loading up these lower permeable zones with contamination. You can come right in and inject the PlumeStop into those flux zones preferentially. And it distributes to the flux zones. It sorbs the contaminants out of the groundwater and coating permanently in those flux zones and making a filter. And as you…over time then, any continuing movement of contamination into that zone from sources of gradient is stripped out, providing for clean water migrating outward into your recovery well or into your monitoring well. So, what we see at sites where we’ve been injected PlumeStop is something like this. I mean, this is very common. On the left, you have nanograms per liter. So, you’re at about a part per billion, 1.2 parts per billion here. To start with… And this is PFOA, PFOS, and other PFAS is in the green. You put the PlumeStop in at time zero there and within a month or two, you’re at below the detection levels usually or certainly below regulatory levels for the PFAS.

So, the next question is, how about longevity? And we’ll get to that. But before that, let me jump into risk and talk about what we are actually trying to achieve here. You heard in Dr. Rosa Gwinn’s presentation the interest in blocking pathways into contaminating water. Well, that’s exactly what we do. We eliminate the risk of PFAS by tying up the contamination within the aquifer itself completely eliminating the risk to the population downgradient. Risk is equal to hazard times exposure. And so, you know, if you have a hazard to the subsurface and it’s a potential for exposure, then there’s a potential for risk. PlumeStop in the subsurface binds up PFAS, binds it up in situ. You don’t have to pump the water to the surface. You don’t have to expend that energy and the time and the dollars to pump it to the surface, and then take it out of the water, and then take it to a landfill. Instead, PlumeStop binds up the PFAS in situ within the aquifer. By doing so, it eliminates the potential for exposure. And by limiting the exposure, you eliminate the risk. It’s that simple.

So, the question of longevity, we actually covered this in a previous webinar. In the past when we’ve injected PlumeStop into sites, particularly one in Canada, we didn’t realize that it was being injected to treat PFAS, but it turns out that it was being studied by a research crew in situ remediation solutions with a very well trained competent hydrogeologist, Rick McGregor. And an associate of his at Porewater Solutions, Dr. Grant Carey, is a world-class fate and transport modeler in the subsurface. Together they modeled how long an injection that had occurred, an injection had occurred to treat PFAS on a site, and they wanted to understand how long it might last in terms of its performance. And they came out with numbers in the orders of decades and decades, 50 to 100 years with one injection of PlumeStop it would stop the PFAS on that particular site. So, we’ve been trying to refine models, but I can tell you that injections of PlumeStop in the subsurface to treat PFAS will last decades with one single injection. And if in 30 years you start to see a breakthrough, you can simply re-inject more PlumeStop to treat PFAS.

So, what are the advantages of PlumeStop treatment? Highly effective at eliminating the risk of PFAS in situ. PFAS drops right off within the zone of PlumeStop treatment and will eliminate the risk for decades downgradient of the injection. It’s very cost-effective. And just to give you an idea of how cost-effective it is. Again, on that site in Canada, it was a very small site. The total install for a pumping system and treating system was around $150,000. But then they would have to operate it for 20 years plus. So, just looking at 20 years of operation plus the install was about $1.3 million. At that particular site, $73,000 was what it cost to put the PlumeStop in. And there is no operation and maintenance. This assumes both cases had monitoring charges. So, the difference in relative costs was about $1.2 million. That’s the savings by using PlumeStop and not having to expend the energy for treatment with pump and treat. And this doesn’t take into consideration the sustainability benefits. By avoiding pumping and just putting PlumeStop in the ground, there’s a tremendous amount of CO2 that’s saved from going out into the atmosphere to generate that electricity to run those pumps.

I also wanna mention that there’s no PFAS waste to handle. When you simply tie up the PFAS in the subsurface, you’re not generating a waste. As Dr. Gwinn mentioned to you earlier, you know, the alternatives for handling waste-generated and pump and treat systems is landfilling or thermal right now. There’s no other demonstrated commercial destructive technologies that are to scale. So, right now you’re generating waste. It has to be either treated in a landfill with disposal or incinerated. And both of those are currently questionable. As her slide mentioned, you know, landfills are shying away from taking PFAS. And I think that’s become very obvious if you’ve had to try to dispose of any. And thermal incineration right now is really in question. The ultimate disposition of PFAS molecules during and after incineration, whether you get recombination products, partial combustion products, etc., is now being studied. But in any way, no matter what you do with your PFAS waste that’s generated, as Dr. Gwinn mentioned, the U.S. EPA right now has moved forward with putting an MCL, a Maximum Concentration Limit, on the treatment of…or, you know, the most… If you have over the MCL in the subsurface in water, you’re going to have to treat it. And that follows from that what becomes CERCLA. And if there’s a CERCLA designation for hazardous waste, if the waste generated from pumping and treating systems, those canisters of carbon or ion exchange resin, if they’re designated a hazardous waste under CERCLA, it’s going to be a very, very expensive proposition to dispose of that or incinerated. Furthermore, joint and several liability follows with that whereby you can dispose with the landfill, but you’ll probably retain the liability for it in the landfill itself. So, there’s a big advantage to not generating a waste, and PlumeStop has that advantage of not generating a waste on the subsurface. And we talked about thermal and landfill questions.

So, let’s talk about PFAS sites that have been accomplished with PlumeStop. PlumeStop itself has been used on hundreds and hundreds of project sites for contamination ranging from petroleum hydrocarbons to chlorinated solvents to pesticides. But with relating to PFAS itself, we’ve accomplished to date 16 sites have been injected and treated with PlumeStop to treat PFAS contamination in the U.S., Europe, and in the Middle East. Right now there’s four more that are in the works right now to be scheduled to go in the ground. And these data actually might be a little old or might be more than that, but it’s in that range. But in addition to that, in the last several months, we’ve seen another 123 projects that are in the design or regulatory approval stage for being treated with PlumeStop. So, these are actual projects where they’re airports or they’re large manufacturing facilities or they are military bases where PlumeStop is in the design or regulatory approval for application. And this is growing what looks to be exponentially with the interest to eliminate the risk of PFAS in situ.

Project types range from small manufacturing facilities that have already been treated. Two major airports have been treated with PlumeStop already for PFAS. Military bases and there’s even a U.S. EPA Superfund site that has been treated with PlumeStop for PFAS. And every project that has been treated has performed as designed with a target PFAS compounds all below regulatory level in all of the sites. And they’ve all been designed for decades of treatment. I think that the oldest one now is going on five years with non-detectable levels of PFAS. So, we fully expect them to be decade’s worth of treatment with a single injection.

And that brings me to where we are, REGENESIS, as a company. And we’ve dealt with, as you see, like, over 100 of these project sites in the design or installation stage. And every place where we’ve put the material in the ground, we’ve seen performance that is corroborating our models. We feel very certain about our ability to treat PFAS compounds in situ. It’s been proven effective, regulatory acceptance everywhere where we’ve suggested it. It eliminates both the risk and the liability associated with the PFAS in situ. There’s zero waste stream. And there’s no mechanical infrastructure or maintenance required. And the longevity last for decades. So, where we are is we’ve now put together a commercial program that we’re calling PlumeShield where we’re willing to come in, sort of, on our nickel, if you wanna look at it that way, and install a system. And the responsible party does not have to pay for it until we meet the objectives that are set out in the agreement. Let me just dive into this a little bit more.

The financial benefits to the responsible party are that there’s zero financial risk. What we’ll do is… Now, this isn’t for every site, but we feel on the majority of PFAS sites that are reasonably assessed, we will look at the assessment, working alongside the consulting engineering firm, we’ll look at the assessment data, and if it meets our criteria, we will pay for any assessment that we need to do beyond that for data gaps. We will pay for the design and we will pay for the installation of the PlumeStop and what we call the PFAS PlumeShield model. We have preset spacing, preset loading into the subsurface that we feel very secure about. And in the agreement that we set forth in the contractual agreement with the responsible party, we will designate specific wells that will be used as the performance monitoring wells and specific goals. And we won’t take any payment from the responsible party until we meet those goals and those wells. And then…and only then does a responsible party pay us a cent. And then if the responsible party wants a warranty beyond that for the longevity of the treatment, we will put together a warranty with you or with the responsible party.

And we’ve talked us through and modeled it and we feel that, you know, we could go into 10, 20, or even 30-year warranties available for the performance of the PlumeShield. And that’ll be a separate agreement. And there’ll be pay as you go type of warranty. It’s not a big capital upfront. It’s just an annual payment to warrant the performance of the PlumeShield. So, we’re very serious about this. And we’ve had excellent performance. And we think this offers a really…I think, a very reasonable alternative for those people in industry and airports and municipalities that are being confronted with PFAS problems and, you know, as we saw, the evolving regulatory framework and the potential of it being considered a hazardous waste. This is, we think, a very palatable alternative for the responsible parties. So, with that, I’ve finished. And again, I’d like to thank everybody for tuning in, and, certainly, I’d like to thank Dr. Rosa Gwinn for her excellent presentation upfront. I’ll turn it back over to you, Dane.

Dane: All right. Thank you very much, Scott. That concludes the formal section of our presentation. At this point, we’d like to shift into the question and answer portion of the webcast. Before we do that, just a couple of quick reminders. First, you will receive a follow-up email with a brief survey. We really appreciate your feedback. So, please take a minute to let us know how we did. Also, after the webinar, you will receive a link to the recording as soon as it is available. All right. So, let’s circle back to the questions. The first question here is for Rosa. And it is, in some jurisdictions, the public has been very vocal about PFAS occurrences. How important is community pressure in driving regulatory action and interim responses?

Dr. Gwinn: Oh, yeah. Thanks for asking that question. There’s no doubt about it that the squeaky wheel gets the grease. And there’s some communities in the United States and elsewhere that justifiably have felt the pinch of discovering that this unknown material is in their drinking water or otherwise in their environment. I sometimes joke, you know, though, that the public thinks that the only thing that should be in their water is H2O. And we all know that, actually, drinking water is a complicated mix of chemistry. That said, when these situations were discovered in the past, and perhaps will be discovered again in the future, there is no doubt in my mind that, especially, in democracies where people have a role in talking to government, it is a driver for immediate response. And given that most regulations have been focused on protecting the population as a priority, I think it will continue to be a way for regulations to be enacted and enforced. Yeah, there’s no doubt in my mind that the public component of finding out about an unusual situation in your drinking water is one way that has really moved along the state by state regulations. I didn’t mention in my presentation, but some of the earliest dates showed a map from 2015 that had adopted some form of PFAS standards or states, generally, where manufacturing of those compounds have occurred. So, I think you can see a one-to-one correspondence, and I think it’s gonna continue in the future. The general public is more educated than they have been in the past. I’m talking decades ago. And that [inaudible 00:53:13] makes for a stronger case. So, yeah. Thanks for asking.

Dane: Okay. Thank you, Rosa. So, we have another question here. This one is for Scott. And it is on the longevity of PlumeStop to treat PFAS. How long can we realistically expect the treatment to last?

Scott: Well, as I said, it depends on how we design it, but we expect decades and decades of performance with a single injection. There’s really two aspects to that, one is how much of the PlumeStop we put in the aquifer relative to the incoming flux of contaminants. But it’s also how long the flow path is that we’ve treated. In other words, if a unit volume of water carrying PFAS moves into a PlumeStop zone that’s only, let’s say, you know…let’s say, 10 feet long so that there’s a torturous path, 10 feet long that the water has to meander through, that will be stripping out PFAS over time. It will eventually become full and you’ll start to see PFAS leaking out the backside. However, if you had designed that to be 20 feet wide, you would stratify the compounds much further and have a much longer treatment period. So, in answer to the question, we have several levers that we can pull in the design of this, but we expect decades and decades of treatment. And we can design it to be longer or shorter in terms of that. And if it does…if you do, at some point, wind up, you know, having a breakthrough, let’s say, 30 years from now, you simply move to a place forward and re-inject it and you’ll have the whole time clock start over again and have another 30 years. Is that an answer?

Dane: Yeah. Yeah. Thank you, Scott. All right. So, we have another question here. This is one for Rosa. And it is, recent U.S. EPA guidance on PFAS disposal identified three currently viable commercial alternatives, landfilling, incineration, and deep well injection. How does the limited available commercial disposal alternatives influence regulations? And is there gonna be a game-changer event?

Dr. Gwinn: Yeah. So, if we go back and hit the books and look at what EPA said, you know, when they first unrolling the whole CERCLA approach, they said, you know, there is a definite desire to destroy the pollutant. Right? That is on their mind. And so I think that’s why their guidance was focusing on disposal. Scott mentioned quite a few items that kind of challenge our general thinking about the benefit of pulling stuff out of the ground, you know, at great cost, and then having to do something with it. So, I think there are a broader set of solutions that are at the table, and they include ways for people to think creatively about at their specific site, their specific need what they should be doing. Still, there are lots of people focusing on disruptive technologies, and AECOM is one of those groups. But there is a literal horse race to determine if there’s some way that in the event, I don’t know, you’ve already got the material on ground surface. I’m thinking of drinking water, biosolids, surface water, and easily accessible places for you to capture PFAS, if you can concentrate and then destroy those, that’s gonna be something that, I think, regulators are gonna ask for.

So, I think we gotta bring all the creative tools to the table. We should be willing to think about what makes the most sense for the site. And sure enough, the EPA said, you know, “These are the three that we got teed up now, but we are gonna keep our eyes peeled and we have a commitment to looking in the future at what new technologies are gonna come out.” And that’s a motivator. That’s a motivator for innovation. One last comment on that. In one of my slides, I did point out that in the United States, there’s the sort of ESTCP program, in Australia, there’s the ARC, and then the EU, for LIFE program. All of those are focused on funding research into good solutions. We didn’t find a solution to conventional contaminants like petroleum products or TC in a week. For decades, we’re still at it. I think that’s what we’re gonna see unfolding ahead of us as well.

Dane: All right. Thank you, Rosa. So, we have a couple of more questions here. This is one for Scott. And it is, how many of the PlumeStop projects that you’ve completed used the PlumeShield program and the warranty?

Scott: Yeah. As I mentioned, it’s a new program that we’re just now launching. So, we’re right now constructing the warranty programs that we’ll be standing behind and we’re just now working with a couple of different clients to launch this where we take the responsibility for putting the system and reaching the goals before they pay. So, look forward to it going forward. And answer to the question, none of the projects that we’re involved in that we’ve put in the ground already were under this PlumeShield program, but I imagined that the majority will be in the future.

Dane: Okay. Thank you, Scott. So, here’s another question. This one is for Rosa. And the question is, drinking water protection seems a primary focus of all jurisdictions. Is that likely to continue in the future? Are there more surprises out there?

Dr. Gwinn: Well, PFAS considerations are always full of surprises. I learned something new every day. Absolutely, drinking water is a priority. I don’t know if folks saw the American jobs plan that has been proposed for by the recent federal administration under consideration. I don’t know who else saw, but there’s a line item in there for 10 billion with a B dollars to mitigate PFAS. And I think it’s focused on drinking water. There’s a… Well, maybe I should rephrase that, it’s focused on water. It’s focused on drinking water, potable water, and also wastewater, including industrial wastewater never intended for drinking water, and probably municipal wastewater, i.e., biosolids and effluents. Those are all under scrutiny and are going to need some way of funding. You know, the wastewater treatment plant didn’t cause the PFAS problem. It’s hard to imagine how they can solve any costly solutions.

Yeah. So, what are their game-changers? Are there out there? Well, I would say that the biosolids distribution was a game-changer. I mentioned groundwater reuse. Even on the East Coast. I’m familiar with an area in Coastal Virginia where water comes back into the aquifer. Eastern Virginia where you think there’s all sorts of water, they are protecting their drinking water aquifers. And when that cycle of water use comes into play, whether it’s what I just described, groundwater reuse in California or when it affects things like beneficial reuse of biosolids, absolutely. Those are each in their own right have been game-changers. There are probably a few more surprises out there, but I think the big worrisome questions have probably come to the forefront already. One way that I think… I don’t know I’m going out on when, I think, I can say that that’s true that some of the big issues have been addressed is when you consider that human blood serum measurement and you see that it’s going down. So, clearly, some of the activities in the past have had a very positive effect. So, I hope that takes a little bit of the fog out of the crystal ball, but it’s imperfect, of course.

Dane: All right. Thank you very much, Rosa. That is going to be the end of our chat questions. If we did not get your question, someone will make an effort to follow up with you. If you’d like to learn more about services from AECOM, you can visit aecom.com. If you’d like to learn more about remediation solutions from REGENESIS, please visit regenesis.com. Thanks again very much to Dr. Rosa Gwinn and Scott Wilson. And thanks to everyone who could join us. Have a great day.