 Welcome everybody, we're being joined by a group online as well. Is that line open and active? Wonderful. Welcome everyone to the spring meeting of the Water Science and Technology Board of the National Academies. Really, really pleased to have a remarkable group here of speakers for today's program. This is the fourth in a series of four meetings hosted by four different boards of the Academy. We chose as our board's component to focus on the topic of PFAS, which is a, for many of us, something we're learning more about for others. It's something they have been steeped in for the last 10 or 15 years. The materials from this and the other meetings will, in fact, be available online afterwards. Participants, if you want to be able to get PowerPoints and so on, that information will be available and we'll send that out to participants. As I said, we, as a board decided that PFAS would be a topic that we would like to explore. We, this has been something that's been, in fact, it's been an issue for many years, but in the general public, this is an issue that has been increasing invisibility in the last few years, including at various state levels and the federal level. We, at the Academy, are interested in this topic largely as a form of education and communication. We want to educate ourselves, the Water Science and Technology Board, about issues of relevance to water. We want to take the opportunity to provide that information and education to others. So we're very pleased to be able to put this on a webinar and have the information available after this meeting. We think of ourselves as a safe space here at the Academy where we can share science, we can share communication, we can share understanding of issues. Leaving much of the political discussion and whatnot elsewhere. So this is a place where we can discuss and educate and learn about what some of these issues are. As a board of the National Academies, we are also interested in learning about whether there's any role that our board and the Academy can play in helping to understand, educate, communicate issues related to this and any other emerging water issues in the nation. So I'm just gonna stop there with that as the introduction, sort of overview of what it is that we're here to do. We have this morning four speakers that will be educating us about this issue from four different perspectives. I'm not gonna take the time to do introductions for any of them, except by name. There's bios in our material that gives you lots of background information about their expertise. We feel really fortunate, as I said, to have this panel who were all available to come and speak to us today. Rula Deeb is from Geosyntac, Maureen Sullivan from the Department of Defense. Ginny Yingling from the Minnesota Department of Health and Peter Gravat from EPA are our panelists and they will be speaking in that order. We are gonna focus on about 25 minutes of presentation from the speakers. We plan to just take clarifying questions after each of their individual talks and to be sure that we have time to get all of the presentations done in the period allotted. At the end of this session, we should have time for some more general open discussion to the entire panel. And for those of you continuing with us throughout the day, we will have an extended period of time for Q and A and discussion this afternoon. So with that, I'm going to turn it over to our first speaker, Rula Deeb. Good morning, everyone. I'm thrilled to be here and very excited that the board is interested in funding a study on this topic. I think it's really important to lend more credibility to what's turning out to be a very contentious issue. So it's also hard to give an overview of PFAS in 25 minutes, but I'm gonna try really hard. I may have to speak a lot faster than I usually do. So my apologies in advance, but I've been asked to give an overview of the technical and regulatory issues associated with this family of compounds. So I'm gonna talk a little bit about nomenclature, uses of PFAS, sources to the environment, and then I'm gonna briefly touch on occurrence, fate and transport, toxicology, regulations, regulatory drivers and other drivers, as well as treatment. So starting off with nomenclature, the correct terminology for this family of compounds is PFAS, which stands for fur and polyfluor alcohol substances. You hear a lot of names getting floated around. PFCs was used for a long time, but it's actually the wrong terminology because PFCs or perfluorinated compounds are just one of the families of PFASs. So all PFCs are PFASs, but not all PFASs are PFCs. And then you hear mostly about the two famous compounds within this very large group of synthetic organics. You hear about PFOA and PFAS, but they're two out of thousands of compounds. So it's really important to keep that in mind because it's not just about PFAS and PFOA. PFASs as a family is a lot more complex to deal with for us in the environmental industry. One thing I wanted to say, these compounds are completely synthetic in nature. They're not present in the environment from natural sources. The most important thing about the chemistry is that carbon-fluorine bond. It is the shortest but strongest bond in nature. So it takes a lot of energy to break it down, which is why these compounds are used so widely. They're great performance chemicals, but that also lends a lot of complexity when we're talking about treatment because a lot of the conventional methods that we think about involving biological or chemical oxidation or reduction involve breaking that bond and that bond is very hard to break. So you've got the perfluoroalkyl substances and the polyfluoroalkyl substances. The perfluoroalkyl substances include compounds like PFAS and PFOA, which have eight carbons. They are compounds for which all the hydrogens on all the carbons, except those associated with a functional group, have been replaced by fluorine. So they're very persistent compounds. The polyfluoroalkyl substances are compounds for which all the hydrogens on at least one, but not all carbons have been replaced by fluorine. So a lot of the replacement, a triple F, the foam that were introduced included fluorotelomers. The thing about fluorotelomers is that they have a weak link. And so in the environment, that weak link can be oxidized by bugs or by chemicals. So they end up breaking down into potentially persistent compounds, which are the perfluoroalkyl substances. So a term that we're starting to use in the industry is precursors. And we're concerned that in the environment, there are precursors to these more persistent family of PFASs, which is the perfluoroalkyl substances. So a little bit more about the chemistry. So the carboxylic acids before, for example, and the sulfonic acid, acids like PFAS are just a small fraction of PFASs. So if you're looking at this figure here, which is from a colleague at NC State, you'll see that the PSCAs and the PSSAs are just a fraction of PFASs. And again, you've got FIFOA right here and PFOS right there. These are the perfluoroalkyl substances, but then you've got shorter chain compounds and replacement compounds that are, we're starting to hear more about them. One great example is GenX. So GenX is a, is being found and is getting a lot of attention in the Cape Fear watershed in North Carolina. And it's drawing attention to the shorter chain and other PFAS compounds that are not within the PFCA and PFSA family. All right, in terms of uses, I mentioned that PFASs are very persistent. Very strong and stable compounds. So that's why they have so many uses in industry. They're used at surface treatments and coatings for carpet, upholstery, clothing, food packaging, and most importantly, non-stick cookware, but they're also really good performance chemicals. They're used for misuppressant purposes. During chromium plating, they're used as lubricants and perhaps the use that has been attracting the most attention is they're used in A-Triple-F. With A-Triple-F being aqueous foam forming foams and the reason A-Triple-F is so effective at putting out a fire is it's, the PFASs act as surfactants. They cover the oil and they can put out, it can put out a fire in 60 seconds, which is really important at airports and military bases where you have a two minute response time to get to a fire and a one minute response time to put it out, it's about saving life. So A-Triple-F is extremely stable. Even when you have a fire that burns at really high temperature, it does not break down. So a little bit about A-Triple-F, it's a proprietary mixture of fluorinated and hydrocarbons surfactants, water, corrosion inhibitors, solvents. PFASs is just a small percentage of A-Triple-F. A-Triple-F has gotten a lot of attention because of its uses by the military, but it's really important to remember that only 3% of the PFASs that are produced are actually used in A-Triple-F. Out of the A-Triple-F that is being produced, 75% is used by the military and about 25% is used by oil refineries, municipal airports and fire stations and also tank farms. And the most important thing about A-Triple-F is that prior to the 1970 time period, 3M was a sole source supplier of A-Triple-F and they had a proprietary mixture that was primarily PFAS-based, the FOS, but then other players got into the picture and in 1973, National Foam came in, 1976, Ancel, and now there's very many producers of A-Triple-F, but it is a proprietary compound. So you might find different kinds of A-Triple-F at the same site. And although PFAS-based foams may not be used right now, the ones with the fluoritellumers can degrade to form some of the carboxylic acids and the sulfonic acids that are of concern. So sources include manufacturing processes, sources to the environment of PFASs, the carpet industry, the combating industry, any petrochemical industry, aerospace, airports, the military, and then very importantly, the stuff ends up in wastewater treatment plants. Our systems are not set up to remove these compounds during wastewater treatment. They get discharged into surface water bodies. The treated water does, ends up with somebody else's drinking water source, gets concentrated in biosolids which are then applied in land farming applications and end up contaminating environmental systems. So you might ask, well, we've been using this stuff for, you know, prior to the 1950s, why are we starting to talk PFAS now? PFASs are not detected using conventional analytical tools. So when we were going out in the 80s and 90s characterizing gasoline contaminated sites, we were using gas chromatography and then when we started looking at chlorinated solvents that was the same thing, GCs don't detect PFASs. So the first clue to the presence of something different in groundwater was foaming at, you know, at, at wells and commercially available management techniques only became available commercially. There's a lot of specialized labs and academic labs that were able to detect these compounds but only in the last 10 years that the commercial methods make it out to practitioners at the ground. So that really contributed to PFAS emergence and of course the media helped a bit. So in addition to soil and groundwater, we see PFASs and municipal drinking water supplies. This is a figure that was developed using the UCMR3 data in what you're looking at here are UCMR3 data for PFASs where the red dots are indicative of PFAS and PFOA collectively exceeding the EPA drinking water health advisory which is a 70 nanogram per liter. Level and the yellow dots are where PFASs are detected but under the lifetime health advisory limits and then the green dots is the non detect but you can see occurrence across the country for, for PFASs that UCMR3 in addition to PFAS and PFOA has four other compounds on it but the EPA method that is being used to characterize a lot of our drinking water aquifers and drinking water sources is a method that only measures 14 compounds, 14 individual PFASs and colleagues at academic class are able to measure up to 3000. So in addition to soil and groundwater, drinking water is important to also recognize that you can find PFASs in form water in biosolids and landfills and there's good documentation of that in the literature. And then the interesting thing about landfills as David reminded me is that if you've disposed of the polymers, they're really not that stable and they can degrade to form compounds of concern to us. So there's the whole issue of fate and transport and landfills that is of concern. So as far as that fate and transport, we know that the sorption of these compounds in subsurface environments generally increases with the number of carbons. So the shorter chain compounds move a lot faster than the longer chain compounds. The transport is also impacted by the char state of PFASs. So you've got anionic compounds compared to cationic compounds that really impact their transport. And then the poly fluorinated substances I talked about the whole issue of precursors that is becoming more acknowledged in our industry. So there is the potential for these longer chain compounds with the weaker links to break down into the dead-end products of concern. The ones of concern right now are the PFSAs, the sulfonic acids like PFAS and the carboxylic acids like PFOA. They're not readily biodegradable. We did work with a lot of university screening while micro organisms that can degrade other emerging contaminants like one for the oxen and NTVE and over 300 organisms that were tested could not touch PFAS and PFOA. They're not transformed in the absence of biology and they tend to be fairly mobile. We're seeing really long flumes in subsurface environments. As far as the toxicology, the data that is available is prevalent for PFOA and PFAS, but not so as much for the other compounds. So there are US EPA published reference doses for human health, PFOAS is of concern because of potentially reduced birth weights PFOA been shown to suspect it of having developmental effects in bones and accelerating puberty. There's also some kidney and liver information that is becoming available that is of concern and the aquatic toxicity data, especially in areas with surface water bodies is suggesting that these compounds bioaccumulate in fish and invertebrates. As far as other PFASs, the information on their toxicity is not as readily available. So here we are, we're using these above ground treatment systems who are targeting the C8 compounds, but the shorter chain compounds are coming straight through off of our systems and we don't really understand the health impacts and everybody's looking for EPA and other organizations to shed light on this issue. As far as biological fate versus like their fate and plants, it really depends on the carbon chain length. But what we're seeing is that these compounds are detected in nearly any biological tissue, be it human tissue or tissue and polar bears in the Arctic. They tend to partition to protein not as much to fats and lipids. They're not metabolized very readily in the human body or in vertebrate organisms or they metabolize to the persistent PFASs. And they tend to bioaccumulate in animals and plants. Although plants tend to, because it's a water pathway, they tend to bioaccumulate stuff a little bit differently than animals. Human exposure pathways, the dermal pathways not as critical. So you see pictures of kids making snow angels in the fumes. The dermal pathways not as critical. It's really the ingestion pathway. So any drinking water impacts or dust ingestion or eating plants or animals that have bioaccumulated PFASs. And then what makes it really challenging for us when we're trying to think cleanup is, a cleanup should really be informed by risk assessment. And there's a lot of risk assessment challenges because again, it's not just about PFAS and PFOA the advisories and the toxicity data is only available for these compounds. So what about all these other PFASs? And there's really no standard guidance or models for risk assessment for these compounds. As far as the regulatory approaches, in April of 2016, the provisional health advisories were finalized and we now have, I guess, a cumulative advisory for PFAS and PFOA to not exceed 70 nanograms per liter, which is fairly low compared to a lot of other contaminants. Now, in the absence of enforceable cleanup standards, a lot of states are coming up with their own, cleanup standards, Colorado's working on something, New Jersey issued their own cleanup standards. And you're gonna hear from Ginny later today about what the state of Minnesota is doing as far as cleanup in the absence of enforceable standards. So a lot of states are coming up with their own criteria and they're coming up for criteria, not just for PFAS and PFOA, for example, Texas has 10 PFASs in addition to PFOA and PFAS. And on as far as regulatory drivers, under CERCLA, PFASs are not yet classified as CERCLA hazardous substances. So you can't really do cost recovery for super fun, but I guess a little bit of a loophole is that if they're considered a CERCLA pollutant or contaminant, you can investigate them. And then there's site investigations and management, at least for our clients where we're seeing a lot of voluntary actions taking place by proactive industries litigation as a huge driver at a lot of our sites. And then there's other variable approaches and drivers at state level. So I'm gonna end with one slide on treatment because David Tadlak is gonna talk more about that later and the treatment issue is a challenging one because of the stability of these compounds and also the complexity of the mixtures and the impact of these other compounds on trying to treat for PFAS and PFOA in mixtures. There are no destruction technologies that are currently available. So we're going back to, we're defaulting to pump and treat which we've tried so hard as an industry to move away from. There's lack of proven or demonstrated incident treatment methods and the available technologies that really do not address the SOARP PFASs and the precursors. We're targeting PFAS and PFOA. So you've got compounds that are highly persistent that are fairly mobile in the environment that are expensive to treat, that may be very toxic and that ones that were released at high volumes because they've been used because of their very unique and stable properties and that kind of creates the perfect storm really for the environmental industry. So just to summarize within the 25 minutes I might finish three minutes early. I hope I didn't talk too fast but just reminders and take away messages. PFAS is more than PFAS and PFOA. PFAS chemistry is complicated and the mixtures are complex. PFASs have been produced for decades. 10, like six, seven decades they've been used in large volumes which creates the potential for reopening sites that we've already closed because we thought we've cleaned them up or creating new sites. Multiple states have issued standards and guidance for PFAS and PFOA and some have issued ones for other PFASs in the absence of enforceable federal cleanup standards. Treatment is challenging and costly and this is not just a US issue. This is huge in Australia. Europe started talking about this way before we did. Canada is extremely concerned about the impacts that they're observing. So this is not just a US issue and the state of knowledge honestly on a daily basis continues to evolve. So I just wanted to leave you with some of the biggest drivers that I see as a practitioner and it's all the media attention. I get about a call a day from attorneys looking to benefit from this issue and of course you, as far as the role of the media I'm sure everybody saw the political article that was three days ago. So I'm gonna leave it at that and are we gonna take questions now or move on? Yes, they're fine as well. So thanks really. Given the mobility, how effective is pump and treat? I mean, because the end of sorption is it something that they're gonna have to pump and treat in perpetuity or does it move well enough? So we're targeting the mobile compounds that does not clean up source zones. We see a lot of sequestered mass of the longer chain compounds and the precursors in source zones but it's effective at hydraulic control and then when you get the stuff above ground there are other technologies that David will talk about like granular activated carbon and ion exchange and other separation technologies but the cost compared to B.Tex and coordinated solvents is more prohibitive. Chris, did you have a question? Yes. Nice presentation, Rilla. Chris Weiss, National Institute of Environmental Health Sciences. You mentioned that dermal exposure is not as great a concern but with 3,000 different chemicals it's hard to imagine that some of those are not dermally permeable and given potential exposure in hot showers and other dermal contact with water we would be interested in references on dermal permeability. I'll send you the references of what is published and available but you bring up a really good point. We don't know about this, 2,900 some compounds that have not been studied, right? That's a big question mark not just for toxicity but for everything else. You need some money to do some studies on that, Chris. If you're going to look at dermal you may not want to look at only what comes from water and the shower pathway and pools and whatever else but what's in my tie that keeps the wine from staining it and what other carpet kids were all around on carpet what are the other dermal exposure pathways for those 3,000 other epithas that might be out there? It's a huge unknown. Fibers and carpets that you're inhaling. Harbour floors. Wonderful, thank you so much. That was absolutely outstanding. Really appreciate that. We're going to move on to our next speaker we're really fortunate to have Maureen Sullivan joining us from the Navy, please charge ahead. Press the button first, right? First of all, thank you all for having me. Second of all, I want to say a cautionary standpoint up front I am totally a policy wonk so any of those highly technical questions we'll turn to Rula. Let me just say well, I'm going to focus on epithas, epiphoa that's what the department is focusing on right now and although this is a national issue of drinking water DOD is proactively addressing epithas, epiphoa and our priority is to protect human health in drinking water exposures and to address the long-term through our circular process. So I'm going to talk to you a little bit about what we've done so far. So there's a little way of a background under Rula mentioned the unregulated contaminant monitoring rule back in the final was 2015. So the Department of Defense is a purveyor of drinking water. We also buy drinking water from local municipalities but we are a purveyor. So we in fact did have 63 systems that met the criteria for the UCMR only one detected above. Now to give you a little context here because we run numbers there were 5,000 public water systems that were sampled under the rule. 63 showed exceedances. So that's 1.5% of the 63, one was DOD so 1.5% of the 63. So to give you scale of where it is. In that one system was at Wright-Patterson Air Force Base and we took that out of service. But then when EPA issued their Lifetime Health Advisory which is in fact an advisory it is not a require regulation. We had a choice on what we would do in the Department of Defense related to drinking water. As any other out there purveyor of drinking water because it is an advisory what we're gonna do. And we made a choice to as a concerned consumer to cast all of our drink where we are the purveyor of drinking water everywhere around the world. So not just in the United States but worldwide. So those were 524 systems that we operate. We identified 24 systems that were above the Lifetime Health Advisory. That's 4.6% of all of the systems we operated. We buy from local municipalities in some circumstances. In those case we requested from the regulator the purveyor if they had in fact tested and identified 12 systems. So that's the drinking water situation for us again under the Health Advisory and this is a voluntary reaction. So then we have the issue of okay what is our circular responsibility? And as Ruella mentioned it's not a Pluton or container I always get the terms wrong. So thank you, thank you. My team here is helping me. Heather a substance. However there is a reference dose that's behind those Lifetime Health Advisories. So we do have to roll it into our circle of responsibilities. It gets very complicated. But what we did is we first targeted where in fact we had known or suspected releases and where those releases were in fact impacting a drinking water off our installations. So we started right away on that focus starting after the Lifetime Health Advisory was issued. Now normally in the cleanup program just to give you context D&D's entire cleanup program we have 39,000 plus sites around the country. Right now I'm sitting on a liability of about $27 billion worth of cleanup requirements not including PFOSPFOA. So I don't at my level track chemical by chemical. However Congress asked. So we did a one time tracking and we created a report to Congress which is available at that website. So as you can see the number of off base systems that we tested and which ones tested above the Lifetime Health Advisory. For those circumstances where they was tested above the Lifetime Health Advisory we worked whether it was a private owner or a municipality. We're working with them on what the remedy is whether it is assisting the community with additional treatment technology whether it is booking a homeowner up to a local distribution system, providing bottled water whatever was right for the circumstance there. Again the concept is break that pathway of exposure. I want to caution you that that was a one time effort to collect that chemical specific information for PFOSPFOA only. So we're not, we haven't been tracking it then since then. The work is continuing to go on. You're not centrally reporting it to me. So my Navy counterpart is like, well, I'm not collecting it in my office because Deb's head won't explode. We don't have that. So then the next part is of course going to the groundwater. So that again, following the circle process that's what we're doing. So we, and as Rula mentioned you're gonna have a mixture. We're gonna have sites that are have other contaminants that are already in our cleanup program. So example of fire training pits. There were other compounds that were used in those pits. So now we're just going back to look at those sites to see what these two additional substances. But we also have some new sites that didn't have other compounds. So for example, crash sites that are involved. But this is for those of you who are familiar with CERCLA it is a very deliberative process that you have to go through. There are very specific steps and at each step there's a decision-making process. We work with that through that process in partnership with the states and with EPA where the sites are on the national priority list. So it is a transparent process because all the documents have to be posted. Most of these locations have what we call restoration advisory boards where there is a, which are local citizens who are interested. So it is in fact a transparent process where we're going through that looking through the groundwater to figure out. I'll admit we're early in this process. We're probably pretty much through the preliminary assessment site investigation process ready to start moving into the remedial investigation feasibility phases. I can tell you generally from my perspective we're gonna have more at Air Force. The Navy is a close second because of the aviation missions. The Army very little. Their aviation mission is helicopters it's much smaller than the aviation mission associated with the Navy in the Air Force. I can tell you a couple of things. I know you're a science group but I have to think about these things between May of 2016 and December of 2016. We spent $200 million just trying to figure out the initials. That's just between May and December. I don't know how much I've spent since then but I can tell you none of it was programmed. So I had to reprioritize all of us in the department to reprioritize our dollars to figure out how to address this problem which is created to each challenge. That means other cleanup work had to be delayed or put to the side in order to address this. I have done a really, really rough back of the envelope calculation. So for just PFAS and PFOA I think our liabilities gonna grow by about $2 billion. So in the department of defense and that is a very, very rough back of the envelope estimate. Just some data on the groundwater sampling that we've done. You'll have these slides so you'll be able to look. I do want to say also on that webpage that is on an earlier slide we had to do a report to Congress. Technically a briefing to Congress that has the data through August of 2017 and it shows everywhere that each location where we exceeded the lifetime health advisory and there's a section on drinking water on our installations drinking water off our installations and groundwater. So it gives you the site by site information and that is all publicly available. So talking about the phone and most people think AFFF stands for Aircraft Fire Fighting Foam. So it doesn't but. So as a little step back here prior to the lifetime health advisory in January of 2016 we actually issued a policy because we could see certain things were going on and of course we had the preliminary health advisory of 200, 400 in place. And so we said to the military departments that when you use the phone to more actively manage how you use the phone. So number one, if you in fact have to have on a land-based fire and you have to fire off the foam that you had to control it in the releases on shipboard applications, fire away. The number one priority on a ship is put out the fire. You have to do that. We also realized that so we have the foam in equipment so fire trucks and things like that on the runways. We also have it in hangers and then we also had it in warehouses, back supplies. So we said, okay, all the warehouse supplies go through and remove the older versions of the foam. So the ones that contain the PFAS take them out of supply and we're disposing of that now which is creating a whole different challenges in terms of capacity. So to try and control and then for training purposes not to just arbitrary release the foam that it had to be more careful. So we're really on a more trying to control the releases of it. I want to again, remember what Rula says, we're only, this is a nationwide problem. There are multiple sources but I wanted to show you we're trying to control ours. So the Department of the Navy owns the military specification on the foam and they're doing a lot of work with the manufacturers and Richard Mock is here from the Navy and he has a lot more information than I have on it. It's proprietary as Rula said, so it's a lot of questions with them of what's in the foam now that they're producing for us. I do want to share with you that they say, well, there are trace amounts and the trace amounts are parts per million and of course we're in parts per trillion category. So this is new for the manufacturers as well. So it's ongoing challenges associated with the foam replacement. This afternoon, Andrea Leason is gonna be here from our Strategic Environmental Research and Development Program and she'll talk more about all of the research initiatives we have going on so I'm not gonna go into any detail about those, she will give you a lot of information. We are partnering with the Interstate Technology Research Council to help get information out to the state regulators, all sorts of technical information and we really appreciate the support from the ITRC. They've published a number of papers on the history and use, naming conventions, fate and transport, site characterization tools, remediation technology so there's a lot of information that the states are trying to get out to all of their folks. So challenges, I know I have a big list here so I'm gonna start at the very top. So for those of you who have had the experience of working with Congress, it creates interesting challenges. So Congress has in the 2018 National Defense Authorization Act, it directed the agency for toxic substance and disease registry to do a national health study exposure assessment on not less than eight military installations and a health study, a nationwide health study on PFAS. They are selecting the sites, ATSDR is selecting the sites, they will be conducting the study. They have not selected the sites, they have not established the criteria to select the sites and the other complication is the money is supposed to come from the Department of Defense. So we were given $10 million, it gets very confusing. It's a lot of back and forth but the bottom line is we were given $20 million in FY 18 to give to them and I don't have a way to give it to ATSDR so due to all the rules. I can get them 10 million but the 10 million has to be sent in FY 18 and it has to be spent by ATSDR themselves or by contract. I cannot send it out by grants the way it's given and it can only be for PFAS before. So we're trying to work with the congressional staff to get all this fixed but when you saw, Rula mentioned the political article, the health study in the political article is in fact this health study, is not this health study I should say, it is not this health study. It is, ATSDR is working on toxicological profiles in minimal risk levels and that's the quote health study that the political article was talking about. So not this health study but the development of the profile. Rula mentioned the state laws and standards. We will for a properly promulgated non-discriminatory standard, we will follow it. We'll roll it into our cleanup program. The challenges for us is keeping track of what all those standards are in the state of play because it is evolving very rapidly. So the cleanup standards. The problem is that we have under the safe drinking water we have a lifetime health advisory but we're operating for mostly this is under the circular process. So we've been pressing EPA, the office of land and emergency management to come up with their cleanup guidance. So what is the correct way to roll these numbers into a circular risk assessment and how do you go about that process? Our interest is to make sure that is in fact being done consistently by all the EPA regions and we have a common understanding of how we're moving forward. They've said that they're going to issue some guidance in September. I really hope they are because we are approaching that phase of the cleanup program, the remedial investigation feasibility study. This is where we do the risk assessment. So we need to understand how this all translates. It gets very confusing and I will really admit I am not an expert in this world. But as I understand it, if we take the reference dose behind the lifetime health advisory and run it through the circle risk assessment the number comes out somewhere around 400 parts per trillion. So how do we explain we're cleaning up groundwater to 400 parts per trillion versus the 70 parts per trillion for the lifetime health advisory for drinking water? Even though there's a long way between drinking water and groundwater but we're looking to EPA because this is their expertise in the area. I don't need to go to, because Rula did a good job of explaining PFAS, PFOA versus PFAS versus PFCs. We get that all the time. That's a constant issue for us talking to the health. We get asked all the time, would it help if the EPA came out with an MCL? Of course, having an MCL in the cleanup process gives us certainty, but we're not going to presuppose the outcome of it. We've said it's up to EPA whether or not they're going to go through the process. We support going through the process because the process is, it's a known process. It's a transparent, involved peer review. And so you can't presuppose the outcome. We are, GAC is the solution that we're using at all sorts of locations. And now you have a disposal of the contaminated carbon to deal with, sorry, this is repetitive here, probably the cleanup standard is going to be a challenge. For me, what I have to worry about is programming for the requirements. So the Department of Defense budgeting process is very convoluted. I'm not going to make you experts in the budgeting process in a short period of time, but basically I'm already building right now, we're already building the budget for 21. So when this rule came into effect in May of 16, we had already submitted the 17 budget to the Hill, we had already developed the 18 budget requirements. So we're not, we were in no position to be able to build the budget requirements for this until now. So up until now we're just begging, borrowing and reprioritizing in the circle workload because we just didn't have the time to respond. And I realized I skipped over risk communication and I apologize for that. That's probably one of the biggest challenges. How do you communicate the risk associated with these compounds to the communities? We are facing that challenge everywhere. And as more work is done on these other PFAS compounds, we're going to face the same challenges. How do we communicate the risk associated with this? And I would say from my standpoint, that was our number one failure in terms of when this all started back in 2016 is we really did not do a good job of communicating the risk and explaining to folks who are smart but not necessarily ruler at level of expertise that what is the risk that we're talking about and what does it mean for these individuals, their health, their children's health. So it continues to be a challenge. So in conclusion, again, policy perspective. Again, DOD is a small part of the nationwide challenge here but we're really trying to step up to address what we're doing. We have in fact committed the resources to be able to do what we need to do. We've reprioritized to make sure we have the funds. And our number one priority is to cut off that human exposure through drinking water. And now we have to move into this deliberative process that CERCLA is to address the long-term challenges. So thank you. I kept to my time, didn't I? Okay. And that'll thank you very much, Maureen. That was an outstanding briefing about what's happening in the Department of Defense and sister agencies. That's really, really helpful. We definitely have time for several clarifying questions. So thank you very much for the remarks, Maureen. I noticed you talked exclusively about drinking water and human health. In the San Francisco Bay area for the last decade or so, we've seen levels of PFAS compounds in marine mammals and in birds, including an endangered species, the clapper rail that have been above levels where we expect deleterious effects. And so I'm kind of curious about what DOD is doing with respect to eco risk and sediment contamination because it seems like a lot of your sites are located proximate to places where there's potential for ecological exposure. I only admit I'm not an expert on ecological exposure other than I had to deal with the cranberries at Cape Cod. Cranberry, the water wet, if anybody knows how you harvest cranberries, you flood the bogs and the water that they used had PFAS before. It will fold into the circular process. I would say it's too early for us to know. The sediment would be part of the process. It is a challenge to be honest with you because fishing is an issue now in Michigan, even though there's post-designs don't fish. So it is that chain that is gonna be a challenge and there's a lot of unknowns here. Again, we're looking to EPA's Office of Land and Emergency Management to come out with their guidance in these areas of what the requirements are gonna be related to the circular process. Yeah, I would just recommend that you also think about the Endangered Species Act because there are many legacy sites that might be contributing and so it's the Clean Water Act and the Endangered Species Act as well as just the human exposure pathways. Right, but right now we're only dealing with advisories. So that's the challenge here is so what is the regulatory structure and Peter's dealing with this every day and it's not just the Department of Defense, it's anybody who is it. So what are the requirements for wastewater treatment, for stormwater treatment? We're all struggling here, so I understand. Maureen, that was excellent. Is the Coast Guard also participating with you in this or are they off on their own? Coast Guard is part of Department of Homeland Security so I really don't know. So honestly, have you heard anything, Richard? I'm not aware of what the Coast Guard is doing right now. I know the only thing that they work on collaboratively with us is Uniform National Discharge Standards, which HWF is one of them, but it basically says don't discharge in the ocean unless you're greater than 12 nautical miles out, so. The other big player is NASA, so because of the launch facilities, so. Wonderful, I think, oh, you want one more? Can you explain the limitation on focusing on PFOS and PFOA and is this a limitation that applies to all federal agencies or is this just a DOD focus? No, this is, it's not just federal agencies, it's anyone in the circle process. So, and there is one other compound that has a reference dose of PFB, PFBF, I always get it wrong, that does have a reference dose that has to be rolled into the CERCLA program, but otherwise there's not, you haven't hit the threshold in terms of information available that triggers a CERCLA requirement to look at. I will say that the ATSDR, that toxological profile in these minimal risk levels, which is the health study in the political article, those minimal risk levels would trigger a requirement to enter into the CERCLA program to look at the process. But right now that's the problem, it's the way CERCLA is structured. So that's why we're looking to the Office of Land and Emergency Management to say, for all people who are subject to CERCLA, what are the requirements? Where is that threshold? And I think we'll take one more question before then we move on. Thanks for any questions, great news, sorry. You mentioned working on the specifications for firefighting foams. I'm interested in what, if anything, DOD has underway to find alternatives to these substances. Good question. I'm sorry, I forgot to mention that. So our Strategic Environmental Research and Development Program, and I think Andrea's gonna answer at this address this afternoon, we have put out a needs assessment for a fluorine-free foam, but it's basic research at this point, but there is a call for we're gonna be investing, spending some money on research to develop a fluorine-free foam. Excellent, thank you again for that really great presentation, and those questions are really helpful. We're gonna move now to views, perspective from the states. You got 50 of them to represent, or at least one. Ginny E. Engling from Minnesota DNR. No, Minnesota Department of Health, sorry. Thank you, and thanks for having me here today, and I will not try to represent all 50 states. It's hard enough to keep up with what we're doing, but I'm a hydrogeologist with the Minnesota Department of Health. We've been working on perfluorinated chemicals in Minnesota since 2002. So we joined the PFAS party way before most people did, and we came to it not through the route that most states are now having to deal with it because of A-triple-F sites, but because of legacy sites associated with a major manufacturer in Minnesota in one of our eastern suburbs, just southeast of St. Paul, and you can see the facility itself is located right here on the Mississippi River, so we've been able to share the joy with our neighbors downstream. And so the reason we became aware of this was in 2002 that company alerted the Minnesota Pollution Control Agency to the fact that the monitoring wells that they had on site, as well as their production wells and their drinking water supply wells were contaminated with, at that time, we called them PFCs per fluorinated compounds. And so they had also previously alerted EPA to the fact that they thought there were problems with these chemicals based on their studies of their own workers as well as American and then worldwide blood supplies and studies were starting to roll in from around the globe about the persistent and widespread nature of these chemicals. And so we were brought in to help assess what exposures may have occurred in the communities near this facility, and of course the first question was where did the waste get buried? They had on-site disposal pits that wastes were dumped to. They also discharged directly to the Mississippi River via a small creek that ran through a little in-letter bay off of the river, and I'll touch on that later. But they also had three major disposal sites scattered throughout the county in the community of Woodbury, Oakdale and Washington County. And then I've also shown on here a dump called Pigs Eye Dump. That was not waste from that facility. It received waste over the years from the wastewater treatment plants of St. Paul. And so even though they're not directly related to that facility, they also have very high levels of PFAS contamination, as Rula mentioned. Wastewater treatment plants are another potential source. And there may be other sources that we're not aware of yet in the area, one of which I'll probably touch on if time permits. Over the years, we've been investigating the releases from those small disposal or those three disposal sites and initial modeling of the groundwater suggested that we would have plumes where the dark shading is shown. That was what we had estimated we would be dealing with. And when we initially started investigating, we were looking only for PFOA and PFOS. Our lab actually developed their own method to test for those chemicals. And we had fairly constrained plumes and we thought we'd gotten off easy. In 2006, our lab expanded their method to include more of the chemicals that early testing through Axis Laboratory up in British Columbia, who was one of the few commercially available laboratories that was doing a larger screening. So they were, at that time, I believe testing for about 18 or 19 PFASs. And they had identified PFBA as being a fairly large constituent in those disposal areas. And so based on their early findings for the Pollution Control Agency, our lab developed their own method that included PFBA because even to this day, Method 537 does not include that compound, which was problematic for us. So as we began testing in 2006, we first started with the wells in the small areas we had already investigated, where we were finding PFOS and PFOA. And lo and behold, we found PFBA in every well we sampled, including the ones we'd previously thought were clean. We expanded our investigation and now as it stands, we've identified an area of over 150 square miles of contaminated drinking water. Four major aquifers, down to about 400 feet below the surface, are contaminated, eight municipal systems supplying over 140,000 residents. We've issued drinking advisories on four of those systems now. And two of them have treatment systems in place. Two more are working on it. We've tested over 2,600 private wells and issued 790 drinking water advisories. Actually by now it's over 800 because we just issued a bunch more last week at individual residences. And as you can see, this is a much larger area than any of our modeling had predicted. And that's down to, or that's attributable to the fact that these chemicals are so remarkably soluble and mobile, particularly PFBA, which acts, in this instance, our geologic survey is thrilled beyond belief because it acts as a tracer for the groundwater. And when we get down to the details of the distribution of this chemical, we can trace out just about every bedrock structure you can imagine when we look at it. So they're having a field day. And so you can see some of those structures highlighted here, the buried bedrock valleys that are tributaries out to the Mississippi and also out to the St. Croix River. We're tracing out liniments and joint patterns and faults. This area is highlighting a major fault block that is of interest to geologic types. What really surprised us though was the implications of the groundwater-surface water interactions. And I think that's been one of the major contributions that Minnesota's work has had in terms of understanding fate and transport. And it's also a cautionary tale for a lot of the sites that people are working on because most of my career, working with environmental contaminants, these highly persistent chemicals tend not to be very soluble. They tend not to be very mobile. If they're soluble and mobile, they tend not to be really persistent. Something's gonna break them down. That's not the case with these. And so surface water groundwater interactions plays a huge role in explaining why we have such an enormous area of contamination associated with this site. And so to piggyback a little bit on what's already been said by Rula and by Maureen, our experience is kind of the poster child of what happens when you're dealing with emerging contaminants. We had our first blush of panic and difficulties but it's ongoing, even though these are no longer really emerging contaminants. We continue to have these same challenges to this day and those involve trying to manage a public health crisis. And truly this for our state is a crisis for these communities. Amidst multiple uncertainties, we have evolving analytical capacity. Even now we're still trying to evolve the analytical capacity to identify these chemicals and now starting to identify precursor compounds and what do we do about those and what are the implications? We have evolving risk assessment. Maureen mentioned the ITRC. We developed a table of all the regulatory guidance and screening values that have been developed by the federal states and other nations. And we are now at the point where we feel we have to update that on a monthly basis just to stay up with what's going on and because of the demand for the information. We have evolving understanding of the fate and transport of these chemicals. Even today I'm still surprised where we're finding them and it's really important that we understand this. And then we have an evolving understanding of the sources themselves. And this is where I think it's really important to emphasize what Richard mentioned in one of his questions. This is not just AFFF. And in fact, in Minnesota, AFFF is the least of our worries. And I'll touch on some of the places we're finding them and Michigan would be willing to stand up and second that notion as they're dealing with waterproofing treatment sites for leather facilities where that's one of their biggest problems. So we have a lot more to do and we're going to keep finding these sites as we better understand PFAS sources. So just to give you a little idea of what we've been through on the evolving analytical capacity, I mentioned that in 2002, we didn't have a method that we could turn to the few commercial labs that were available. We're already working for, one of them was working for the company that we were investigating. And so we didn't want to go to them. The other one was working for DuPont. So we didn't want to use them. And sending samples across the border following 9-11 just was not a great plan because it slows the transfer of any materials crossing the border. So we developed our own method. And as I mentioned, we had to do that also because of the mixture of chemicals that were present at our sites. We couldn't use 537. And the analyte list, as I also mentioned, has evolved over time. So you can see the chemicals that we've tested for. Our list includes PFOA, PFOS, PFBA, PFPEA, PFHXA, PFBF, and PFHXS. So sorry for the alphabet soup. But those are all the perfluoro sulfonates and carboxylates that Rula mentioned, the persistent non-degradable ones. We haven't even begun to touch the precursor chemicals. The problem with having an evolving analyte list and also an evolving method detection limits, and you can see this graph shows how our detection limits have decreased over time down into the part per trillion range, is that every time we go back out and sample a well that was clean because we were only testing for a few chemicals and now we're finding more chemicals or a well that tested clean because we just couldn't detect the low levels at that time, it gives the public the sense that things are getting worse, that we're finding more, we're finding a bigger area that the problem must be getting bigger and uglier and worse. And so it's hard to do the risk communication around evolving analytical capacities. We also have the problem that the analytical methods are outpacing our toxicological studies. So we find chemicals, we cannot tell people anything about and that is a pretty uncomfortable situation for both a public health agency and for the exposed public. We've had an evolving risk assessment for these chemicals and this graph shows you the Minnesota's guidance values for these drinking water or these chemicals. So we have guidance values, both promulgated values for PFOA, PFOS, PFBA and PFBS. And because we know our residents are exposed to PFHXS because we know that the levels in their blood exceed the national average and people are concerned, we've also been using the PFOS value as a surrogate for that chemical because the one thing we know about PFHXS is it has an even longer half-life than PFOS. It appears to have similar modes of action in the body and it defies the rule of thumb that Rula mentioned that the longer the chain, the more adsorptive the chemical is likely to be. It has a shorter chain than PFOS and yet for some reason we accumulate more of it. And so the half-life is apparently around nine years whereas for PFOS it appears to be maybe two, three, four years. So significantly greater adsorption. And yet we have no real information to base a number on. We just had to have something to be able to evaluate the exposures for our residents. Minnesota early on, because we were sort of working in the dark, developed some novel risk assessment approach because our toxicologist said that extrapolating from animal studies to humans in this case was not appropriate because the human half-lives were so much longer than those seen in mammalian counterparts or corollaries. So even compared to monkeys apparently, we have longer half-lives for some of these chemicals. And so they developed a method that uses serum levels and takes into account that long half-life which is part of the reason we have such low values compared to some of the national numbers that have been put out there. And we also have much lower values than the new lifetime health advisory. So instead of 70 parts per trillion, we use 27 for PFOS and 35 parts per trillion for PFOA. And that's based on some differences in our assessment of the uptake or the intake rate for bottle-fed infants and also the body burden on those babies during pregnancy and immediately after they're born. So again, evolving advice and inconsistent advice across the country has led to tremendous confusion on the part of the public. And again, every time we lower our drinking water numbers, the public thinks things are getting worse because we're issuing more and more drinking water advisories. Minnesota also takes an approach that's required of us in statute that we do additivity calculation on chemicals that affect the same organs and have similar mode of action. And this gives us a way to add up the effect of chemicals that have different toxic potencies. And so this is just simple. It's a very simple equation, but it seems to baffle even our engineers. I have to explain it to them over and over. But it's simply all of the detected concentrations divided by the drinking water number. And then you sum that up. And if the total is greater than one, we consider that to be an exceedance just as if a single PFAS had exceeded its drinking water criteria. Now, on our few DOD sites, that's a real problem because that's not how it's being done on the federal level. We have chemicals that they are not dealing with under CERCLA, as Maureen mentioned, and we use a process that's not the same as is done on federal sites. And so it becomes a problem having these conversations about how we deal with these differing approaches. So all of this, evolving, on top of all of this, we've had an evolving understanding of fate and transport and the PFAS sources that we're dealing with. And so as I mentioned, we started out looking at these sites and thought we had fairly constrained, contaminant problems, but the extreme mobility and solubility of PFBAs created a much larger problem. And defining the extent of the affected area is complicated by the fact that these chemicals are so ubiquitous, especially in urban environments. We find PFBA in urban surface water and groundwater pretty much anywhere we look for it. It's probably due to airborne deposition as well as other sources that just simply haven't been identified. And so when we get to the edges of this plume, it's pretty hard to tell what we're actually seeing. And that, again, creates concern because people think that they're being impacted when maybe it's just background and we just don't have a good handle on what background is. It's also further complicated by the possibility of other sources, not only the stormwater sources, but also A-Triple-F. We have a chemical plant, another a plastic facility right in this area that had a major fire. And we think that we have a signature superimposed on our legacy site plumes from that fire. We also have had fire training activities by municipalities in this area. The unfortunate thing we've discovered is that the big open spaces that most municipalities have for where their fire departments can train is their well fields. And so we found that across our state that the place that people were training, their fire departments was right next to or on top of their well fields. There's also other waste disposal activities that may have occurred. We've had a couple sites that we identified where illegal dumping probably led to some of this contamination. Land application of biosolids was also mentioned. And so that may also have contributed to it. And so all of this extreme persistence has created some unexpected transport pathways that we are still trying to fuss out in our area. And that again creates the discovery of new areas in the sense that the problem is getting worse. And this just illustrates that surface water, groundwater pathway, and I won't go into too much detail, but if you can follow the bouncing arrows, light blue is groundwater, dark blue is surface water. And these two sites, the disposal occurred at different times. So they have different chemical signatures. Oh, there we go. They were both discharging PFOS as well as other PFAS into the groundwater. So following the regional groundwater flow, no big deal, forming plumes, that's what we'd expect. But they were also, the groundwater was also discharging to a surface water that flows east. So now it's traveling in the surface water, becomes a losing stream. Now it goes back into the groundwater and wells 150, 200 feet deep have exactly the same chemical signature as that surface water. It was also transported through a stormwater pathway into that creek, into a lake, back into the groundwater, impacting wells down gradient of that lake where we never expected to find it. So all of a sudden we're finding these dislocated plumes. It then travels through both groundwater into another lake. Now it's across a groundwater divide, passes through that lake and into wells down gradient of the lake again at the same concentrations. It also passes through a surface water system there, discharges into a series of ditches and ponds into another lake, back into the groundwater, impacting the wells down there. Now we're like six, seven miles away from the original source areas. It also continues through the surface water system. All along that course it's infiltrating to groundwater, creating a large plume. It gets into a buried bedrock valley, follows it out towards the river. Then it goes into a pipeline, transports to a stormwater pond, back into the groundwater along that stormwater pond and out to the St. Croix River. So this is not something anybody's seen with persistent environmental organic contaminants. It's just not anything we expected. And so we are still trying to find the end of the problem out here because we just found out that it was there. And that's something of a cautionary tale for anyone working on these sites. If there's a stormwater pathway, moving the chemicals off site, you gotta trace it and figure out where that re-infiltrates to groundwater. We've had a lot of remedial actions going on. I know I'm kind of bumping up on my time limit. So I'll try to get through the rest of this quickly. But as Rula said, it's back to the future for these chemicals. All we've got is granular activated carbon right now. There are other technologies for absorption of the chemicals. We just haven't been applying them because we started early and this is what was available on off the shelf. We did do some testing of commercially available point of view systems so that residents could put in their own if they wanted, we supply the carbon filters for homes that exceed our drinking water numbers. But even these small systems like this faucet mounted system, we tested out to try to give them some way that they could take action on their own until we could get to them. Cleanup has been excavation, containment, and pump and treat, including dredging of sediments. So we have done a little bit of sediment work. But pump and treat, all of those sites that I showed had pump and treat systems going and they did not contain the problem. And that's because they were designed to deal with solvents, industrial solvents. And so they were doing a great job on that but they didn't do such a great job containing the PFAS because they just weren't designed for it. Our bio monitoring in the affected community shows that once you take people, give people a clean water source, their concentrations drop off dramatically over time. But people in the East Metro still have averages above the national average for PFAS, PFOA, and PFH excess. We've done studies of garden produce that have given consistent results with some of the lab studies showing some uptake, primarily of PFBA and the shorter chain chemicals. Again, as Rula said, because now we're looking at primarily water uptake and so that's primarily the most soluble ones. Statewide, if there's a silver lining to any of this, that large chemical manufacturer under a consent agreement with the state provided a great deal of funding to Minnesota to investigate PFAS statewide. And so we have done quite a bit of work on fish sampling and consumption advisories which have identified three chrome plating facilities because of high levels of fish in the receiving waters from the wastewater treatment plants that they were discharging to. And those are significant sites for us. Fairly large water systems have been contaminated by these chrome platers. We've done ambient groundwater monitoring, fire training site investigations which also identified three sites with contaminated drinking water systems, wastewater treatment plant effluent landfill sampling. We've found PFAS at every landfill ever tested regardless of the type of landfill, air and precipitation monitoring and the PCA is now working on developing a prioritized list of possible sources to try and get our arms around where all we need to look. So I'll wrap it up with, if I had a wish list of what we need, we desperately urgently need a toxicological study on PFHXS. We have known for over a decade that through the NHANES studies that PFHXS like PFAS and PFOA is in essentially 100% of Americans blood. And we need to know what that means for public health. Just as importantly, we need to know about some of the other chemicals that are typically found, these persistent chemicals that are found in groundwater and drinking water, PFNA, PFHPA and the shorter chain ones, PFPS and PFBA because we're shifting our chemistry to shorter chain PFAS. So we ought to know what that means in terms of human health and what the long-term implications are. Especially as they are the hardest to remove from the drinking water. So if we shift to them and expose more people and don't have good ways to clean them up, then we're creating an even bigger problem. We need standardized analytical methods and Peter's gonna talk about where we're at on that, which is really good news. We need validation of sample collection protocols. There's a lot of urban myths out there about what can happen to your samples and we need to have some reality layered onto that. We need a better understanding of additivity, better information about the uses of PFAS. We do need to get past just a triple F and start talking about other sources and understand their volumes, their timelines and the precursors that were used. And we desperately need more treatment and remedial technologies and much thanks to the Department of Defense for the work that they're doing on that front through CERDA. So, I apologize, I think I ran a little long on you, but that's pretty much what I had. Outstanding, thank you very much. And I think we do have time for maybe one clarifying question. Keep us on time. Ginny, I know you're not trained as a toxicologist and but a lot of the talk is about risk assessment and I'm kind of curious about what other information is available from communities where human exposure was more significant, not just about the levels that people had in their bodies, but the effects that have been seen under the scenarios where there was higher exposure that kind of gives you confidence that you're not just doing all this cleanup for an imaginary number due to the way in which people do risk assessment. Right, so, and that's a really good question because the health effects that are attributed to sort of these lower level or that are linked to, I shouldn't even say attributed yet, we are suspected, are not the kinds that you can necessarily identify in the population, the thyroid effects. How do you tease that out of the larger population? There have been suggestions that perhaps there are more miscarriages or premature births in the affected communities. There was some expert testimony about that. Our data doesn't necessarily bear that out from the health department's epidemiological studies. So it's really hard to know if we're on the right track, frankly, without the toxicological studies to back this up. And so we've taken a very cautious approach with these chemicals because they accumulate and because we have so many people exposed, but we did look at the C8 studies. There's a lot of literature out there, but again, a lot of it focuses primarily on PFOA, PFOS. We've tried to extrapolate as best we can. We have much higher levels for this shorter chain compounds, but yet because of the long-term and ongoing exposure we've taken, it was our toxicologist sense that we needed to be as cautious as we could until we know more. Excellent, thank you very much, Ginny. And our final speaker for the morning is Peter Gravat from EPA. Let's turn it over to him. All right, thank you so much. And those are three terrific presentations that were given by the group here. And I'm a late entrant to the panel of presenters, as I think most of you are probably aware. So I'm gonna give you a presentation that's a bit higher level and is gonna be talking about some of the things that EPA has underway right now, including within the next week or so, that I think will be of interest to folks. And then maybe key off of some of the comments that Rula and Maureen and Ginny made in their presentations. So I think a couple of things that just by way of observation that I think make the challenges with PFAS a bit unique for us is that by and large, outside of some actions that have been taken under TOSCA for these compounds, we're talking about unregulated contaminants. There are no drinking water regulations for these contaminants. They're not listed as hazardous substance under CERCLA as Maureen noted. And there's very little that the agency has out there that is controlling in a regulatory nature for these. That said, all the compounds that are in use today have come through the TOSCA program and there have been evaluations of those programs and some restrictions put in place to address concerns related to some of the very large universe of compounds. So that's one thing. A second thing that I think is really important, maybe makes this a bit of a unique situation, is that a chemical engineer who I talked to characterized these compounds as gorgeous chemistry in the sense that they do miraculous things for us. These compounds are in extraordinarily wide use and are found to be ubiquitous because they are in so many products and provide properties that are fairly miraculous in terms of the breadth of things they can be used for and they can be accomplished with them, many of which we care a whole lot about in terms of commerce. And so, David, I see you like, I'm not quite sure what your thoughts are, but I assume you'll share them. And the reason I make this point is just that it's important to recognize that these compounds play a very important role in commerce today in the United States on things that people really want. And so I think there is both the important drivers for the utility of the compounds, but also raises really important questions about exposures and how best to understand exposures. So there are certainly areas, sites, where there are elevated levels of exposure, and you heard about a number of those in the presentations today, but for many in the population, their highest exposures are likely occurring in their homes and in their food supply, in part because of the products that are in common use, whether it be the stain resistance in your tie, as you mentioned, or the clothing we're wearing, or that's certainly in this carpet or in food packaging, or in manufacture of things like, we heard about electroplating, and the very important role that these compounds are playing in terms of mist suppression, trying to help avoid cancer resulting from exposure to aerosols and workers in the workplace and electroplating, but from Chromium 6. So I mean, there's a lot of things that we have to think about here together when we're trying to understand how to consider exposures, say, in drinking water and in other environmental pathways. Nothing I'm saying is intended to discount the importance of the environmental exposures, just to acknowledge that it becomes very complicated when we have a family of compounds that is so large that is in such wide use, and we're trying to think about what are the risks and concerns associated with exposures in drinking water, for example, one of the pathways we talked a lot about. So in terms of what EPA is doing, what the administrator, what administrator Pruitt has very clearly focused the agency on is in providing tools to states and local communities that are facing these challenges, much like Jenny was talking about in the state of Minnesota, and we see that in some cases, the states are in fact a ways ahead of EPA in some cases, certainly not all, but in some. And these are in broad categories of trying to better understand human health toxicity. We have a couple of toxicity assessments that are underway right now that we're doing with in partnership with other federal agencies in the states, that includes for Gen X and PFBS. You mentioned Maureen, there already is a provisional value for PFBS, and we're building on that work to look at the most recent data, and we're also on Gen X, given the great concern in the Cape Fear watershed in North Carolina, we're building on data that was submitted through our TOSCA program to develop a toxicity assessment for Gen X. These are both gonna be publicly available this summer. Okay, so that is two new things that are coming in, in addition to the reference doses we have for PFOA and PFOS. You talked a lot about methods, Jenny, and we have heard from you and others how important this issue is, and the method 537 for drinking water was really specifically developed to support our UCMR rule. The drinking water systems across the United States are not compelled to sample for these compounds. There is no requirement for them to do so. Once the UCMR study, the National Drinking Water Monitoring Study was completed. So I think it's really also telling to consider the results of UCMR. Granted, we certainly didn't look at hundreds of compounds, we looked at a small set of compounds, and the real focus was PFOA and PFOS because we have the health advisory available for those two compounds. And Maureen made reference, maybe just in passing in your slide, but to the very important data that resulted from UCMR, which is the most robust sampling study of the occurrence of these compounds in the nation's drinking water systems, UCMR3 is where it included the perfluorinated, the PFAS compounds. So we had 4,900 systems included in that nationwide sample. It's a census of all the large systems in the United States. It's a statistically drawn subset of the medium systems and the small systems in the US. We found these compounds above the health advisory levels in 1.3% of the systems that were sampled. So on the one hand, you hear a story like Ginny is telling in terms of the occurrence that you've seen around the former manufacturing or maybe still ongoing manufacturing facilities, but the legacy sites that are there and you think, oh my gosh, this is just, you talked about crisis, public health crisis. And if you look nationally at the nation's drinking water systems, you see a occurrence levels that might make you scratch your head and say, wow, it seems like I would have expected to see more than what I'm hearing about the health advisory levels. And I think that points to the way in which this issue is playing out and almost the surprising way on its face that you see nationally, perhaps not very high occurrence levels, but where these compounds are present, they are wreaking havoc for communities. And it creates another set of challenges for us thinking about, so what are the right sets of tools to address a problem like this on the national level? I'm gonna talk a little bit more about that in a minute. And so methods tremendously important. We are working on expanding 537 to most immediately cover Gen X and looking at the opportunity to expand that to cover other compounds. We also do not have validated methods now for these compounds in other environmental matrices like surface water, sediment, soils. And so someone goes and samples drinking water, whether it's in private wells or in a public water system, they find levels of this that are of concern and we don't currently have the tools available for those communities to try and trace back, at least from EPA's methods. And states have developed some of these and there are certainly methods available, as was noted earlier for many more compounds. I think Rula, you made the point for many more compounds than we have validated methods for at EPA. And so we're expanding that universe of methods over the course of this year. We're hoping to have additional methods available for folks to deal with both additional environmental matrices and additional PFAS compounds within those matrices. And then the last piece is what Ginny talked a lot about in terms of effective treatment technologies. It would be great if there was a silver bullet that would cover all PFAS compounds, but it doesn't exist given the difference of chemistries. And so we're working on developing and communicating more information about effective treatment technologies. The thing that flows through all of this and I think flowed through all of the comments today is the challenges around risk communication. And so you see, I think many communities finding themselves in a very reactive mode and in a place where people will characterize the situation as a public health crisis. And I think because of the ubiquitous nature of these compounds, it raises real questions for us and the ways that exposures occur about how do we best go about talking about these compounds? So we're not necessarily putting people in a panicked mode. Some have referenced, and I think, Maureen, you made reference to our health advisory values. And when we came out with those for PFOA and PFAS in 2016, we provided very little advance notice the agency did that they were coming out and what the numbers were gonna be. And if you look across EPA's current regulations, we have under the Safe Drinking Water Act, both our MCLs and our treatment technique regulations. There are very, very few that even have within them what we would call a tier one public notification requirement, which means when you exceed this level, you have to let the public know within 24 hours that you have exceeded this level. There are very few regulations that include that sort of requirement. In the health advisories, we're talking about a non-regulatory tool that has led a number of communities across the United States to determine very soon after they exceeded that value, non-regulatory value that was developed without any consideration of feasibility of treatment or the cost associated with that treatment. You've seen many communities across the United States determining in a very short period of time that they had to find an alternative water supply for their population, drill new wells, look for going from maybe groundwater surface water, bring in bottled water, provide filters. And so that in itself, and it creates a huge challenge for the population and puts us in somewhat of an awkward place in that we have a non-regulatory value that in some cases is having a greater impact on communities than the regulations we have in place. And so that's a very difficult spot that I know Maureen is living on a regular basis. Next week, Tuesday and Wednesday, the administrator has called forth folks from across the country to participate in what we're calling a National Leadership Summit on PFAS compounds. It's a by invitation only event. It is focused primarily on states. We have 38 states that are planning on participating. Half of those are gonna participate at the commissioner or secretary level, the highest level within the environment and public health department of those organizations. We're gonna have many, many federal agencies represented Maureen will be presenting at that event as well. Chris will be there, Chris Weiss from NIEHS and colleagues from across the federal government. Pat Pryce at ATSDR will also be presenting in that event. And you've read some stories in the press recently about ATSDR and their toxicity profile that Maureen referenced. And the idea of this summit is really the recognition that we are in this together. And as we're trying to identify solutions to this problem, it is not gonna be the best approach to say, EPA is gonna roll up our sleeves and do things like more health advisories and we'll tell you when they're done. In fact, we need to roll up our sleeve together with all the parties who have a stake in this and try and figure out what the most important things are to do going forward and how we do those together. We aren't necessarily looking for a to-do list at EPA coming out of this summit so much as identifying priorities for us to focus on. Following the summit, because it is very important for us to understand the sorts of challenges that Ginny was talking about in communities, we are gonna be traveling to communities that have been impacted by PFAS compounds and having meetings with them in those communities, EPA will be, to try and understand better their challenges that they're facing. And then we will be using this along with the partners who are gonna be participating in this effort, which is a very broad set of folks, including not just dimension states and other federal agencies. We're gonna have the regulated community there, both drinking water utilities and chemical manufacturers. We're gonna have NGOs, such as NRDC is gonna be there, EDF is gonna be there, Environmental Working Group is gonna be there. So some of the big ones that you're familiar with, tribes are gonna be participating in this event as well as a number of associations, both representing state groups and representing, say drinking water utilities and wastewater utilities as well. So it's a broad swath of folks that are coming together next week for this event. The administrator will be participating as will the deputy administrator through much of the meeting. So it is a very significant focus at the highest levels of EPA. In terms of some of the research activities, we're doing additional work on toxicity. I mentioned Gen X and PFBS. We're also working on tox values for additional compounds that we're looking forward to developing in the next year or so. But one of the important points I think for us to think about together is that this problem is not gonna be solved by knocking off tox values for individual compounds one at a time and we'll say we're done when we get to however many thousand we have to deal with. It's not gonna be done that way. At some point in the very near term, we're gonna have to think about how we best address these challenges through looking at compounds as groups, groups of the broad family of PFAS and what are the most meaningful ways to group those PFAS compounds based on different characteristics of either persistence or chain length, bioavailability, mobility. Those are all issues we're gonna have to look at and our hope is that having the reference doses for PFOA, PFAS, for GenX and PFBS and the additional ones that I mentioned are gonna help to point us in some directions along with the read across sorts of activities that we have underway in our computational toxicity center at EPA and looking at other tools to better understand toxicity of groups of compounds. I already mentioned analytical methods, also trying as I said, trying to better understand exposure across different parts of the environment and also household exposures. So I didn't point out among the federal family that FDA is gonna be at this meeting next week as well. Food packaging matters a lot on this issue and we need to think about what's happening in drinking water in the context of those issues around food packaging and carpet stain resistant carpets and those issues. And I already mentioned as well, treatment remediation, trying to make progress. I've already addressed the information that's on this slide I think I mentioned the health advisories for PFO and PFOS and the work that we're doing on the to the tox values. And I mentioned they will be available later this summer and we are working, I don't know that I said, but I'll repeat, we are working very closely with all parts of the federal family on this issue, including DOD, Office of Management and Budget, FDA and IEHS, ATSDR, NASA, looking broadly across the board. In fact, all those organizations right now have copies of our draft assessments that they're reviewing. We're also working with states to try and make sure that we're not surprising our key co-regulators but they're really drawing on the best expertise we have for the development of these values. Maureen mentioned the work at contaminated sites, whether they be federal facility sites or a much broader universe of other types of sites. We are developing cleanup goals. They will be available in September as we have said and they're gonna be going to OMB the schedule is in June, next month. And there's an important piece here of OMB engaging in this issue. It matters a lot what these values are. They will trigger, they will have implications for cleanup across a wide variety of sites. That work is underway. Tosca, I made reference to these points already in terms of what was done in the Tosca program. The stewardship program is a very important and was actually quite effective part of this process in terms of the phase out of the manufacture of these chemicals domestically. And I think one of the points when people ask me and the number of people have, how do you think about these compounds in the context of other environmental contaminants that we deal with? I think the things that come to mind to me are first, health advisory in the units of parts per trillion. I very rarely deal in units of parts per trillion in the work I do in drinking water. I'm usually talking about parts per billion or parts per million. So that's one thing. The second thing is that the manufacture of these compounds, the fact that the manufacture of these compounds voluntarily decided to phase out their manufacture given the incredible value that they played for those companies in terms of their sales tells me something about how seriously the community thinks about these compounds both in terms of their persistence, their bio cumulative nature and their toxicity. That folks said, you know what? We want to get out of this business because this is worrying us. So I think that's an important way to think about these compounds. There's a whole lot more work for us to do together on this issue. And as I noted, we're talking about, for the most part, unregulated contaminants across all of our environmental programs. And there are some real questions that need to be asked about what's the right step going forward on this. The administrator may address some of those issues next week in terms of his perspective on that. But this is going to be important work going forward. So I'm going to stop there. I hope I didn't take too much time. I know I was advertising something closer to 10 minutes and I took more than I said. But thank you so much both for your interest in this and for the opportunity to give you a few perspectives from EPA. Thank you very much, Peter. That's outstanding. Why don't we take a couple of questions for Peter in case they're clarifying questions? And then if there's still time, then we can have open for the whole panel. Anything for Peter initially? Peter, I'm glad you ended on Tosca because that was my question or clarifying question for you. We're so focused on what happens after the horse already out of the barn and coming up with the tox values and cleanup and analytics and everything. And you mentioned up front about Tosca that all these chemicals have been looked at. And Rula said there's 3,000 of them. So I'm kind of questioning what did that look? What did that look look like? And how can we do it better? Because what I would proper is when the major manufacturer took PFOS off the market and when the PFOA Stewardship Program kicked in and that came off the market, the blood levels went down precipitously. And so it's not everything we're doing with respect to dealing with drinking water and groundwater right now. And even the UCMR shows only 1.3% had exceedances of those too. I mean, it was taken out of the marketplace that had the real public health benefit. How can we do a better job of that? Right, it's a great question. And as I mentioned, the compounds that are in commerce today have passed through the Tosca program. We've looked at those and considered in many cases there are restrictions that were placed on the uses of some of those compounds. So one of the things that happens in the new Tosca is the opportunity to identify priorities for additional review. And certainly the agency is looking at the PFAS compounds in terms of whether they ought to be a priority and how they fit in with other priorities. That work is ongoing. They're also, we'll hear from, there'll be a presentation on Tuesday morning from the American Chemistry Council. They'll be talking about some of their perspectives on the current use patterns of these compounds and where they see that work going. There are stewardship programs for compounds beyond just PFOA and PFAS, not in terms of phase out, but in terms of work that they're doing within their membership organizations to try and say, how do we best manage these programs in practice? And Maureen mentioned the important work that's been happening related to firefighting foams on federal facilities. And I know you're involved in too, just trying to recognize the importance of that. One of the things that I'll note about on the topic of firefighting foams I thought was particularly striking is that Heidi Greither told us at the recent ECOS Environmental Council of the States meeting from the state of Michigan that one of the things they did is look at the site where there was application of firefighting foams in response to a truck accident that did not involve a fire, but it was applying the foams as a preventative measure because the materials that were being carried by the overturned tractor trailer were flammable materials. They went back to a site where there was an accident on a highway two years later and sampled the groundwater and found concentrations of 73,000 parts per trillion in the groundwater resulting from a single application of the aqueous film forming foams, which is a pretty striking number when you think about the concentrations that we're focused on. So there's some real challenges there. So thank you very much, Peter, for your remarks. I prefer not to think about 1.3% of the drinking water samples, but these compounds above the notification level in the water supply of 6 million Americans and that does concern me a little bit more. But my question is about the peer review that's going on for the PFBX and Gen X risk assessments. And I'm kind of curious if there's plans to get the science advisory board involved in that peer review. So there are not current plans to have the SAB involved in the peer review, although we will be briefing the SAB on the PFAS compounds in the relatively near future. I think one of the things that the agency is balancing on this that I think you all will appreciate is that the states are clamoring for information here on additional compounds, as Ginny mentioned, there is a great need to get information out quickly. So we're trying to balance that in terms of what's the process we build versus what's the timing associated. I think the administrator's view on this is that his response to governors who are calling him, and this is many governors who are calling him about these compounds and saying, we need a value safe from North Carolina for Gen X, is that saying, well, we'll get back to you in a couple of years and let you know what we think about that is probably not really what we're targeting. We're trying to both be expedient in time but also be very cautious and deliberate in the way that we develop these values, which is why we have both the states and the other federal agencies so heavily involved in this process. Great, questions for anyone on the panel? We have a few more minutes and if there's anybody else, go ahead. The question is whether something might have been missed under TOSCA relative to the original evaluation of these compounds that led to their widespread use in the timeframe that they were being used and whether there's some lessons learned or something that needs to be done on that end of thing? Right, so I think it's a good question, Bob, and I think one of the things we can recognize is we have the Lautenberg bill, which I think was in response, bipartisan response to perceived shortcomings of TOSCA that needed to be addressed. And so we're now working on the implementation of that new process. As I said, these chemicals were reviewed under TOSCA and we now have the opportunity under the new TOSCA to go back and look at some of these and consider whether we need to do something different. So I don't really want to, and this question has been asked a number of times before, is this represent a failure of TOSCA? I don't necessarily want to be either an apologist for TOSCA program or certainly don't want to be pointing fingers at my colleagues as some of them may not have done. I mean, the TOSCA, the older TOSCA legislation was fairly limited in terms of the tools that it offered the agency in terms of reviewing compounds. I'm not seeing others jotting in, so oh, go ahead. I love to ask questions. Ginny, I guess I have a two-part question for you on PFBA, which we're not really looking at, but that was fascinating what you presented. So two things, one, did you find any wells that didn't have PFBA? And assuming the answer that might be no or minimal, have you considered whether or not it makes sense to look at developing an anthropogenic background for that compound? Yeah, that's a great question. And initially the answer was no. So we started to think maybe there was something else going on, and so we tested Teflon components from well pumps because we thought, oh my God, it's leaching out of the pump. Or it's the Teflon paste in the plumber's paste or Teflon tape. And so our lab did leach testing on all of those and could not get anything to come off, which is why I have a healthy dose of skepticism about some of the sampling protocols that suggest that you only can get a clean sample if you go naked. And having showered in a week and God forbid you wear any deodorant or insect repellent or sunblock. So yeah, so then we were concerned because there were rumors that it was in drilling mud. And so our well management program did a lot of work on that and that did not prove out. We do find wells where we don't detect it. The problem is throughout the metro areas I mentioned and then statewide in shallow groundwater, we tend to find it pretty much wherever we look. But up in the Bemidji area, where we know we have impacts from an AFFF site, though private wells down great under fairly shallow and we don't see PFBA. So it's not completely ubiquitous. So I do think that in the East Metro, most of what we're seeing is related to the site. And now that we have lower detection limits, we find some of the fellow travelers, PFPEA and PFHA accompanying the PFBA detection. So, but I do think it's an important point, this the background concentrations and the anthropogenic sources that have contaminated surface water and shallow groundwater. It's important to understand that so that we can put some of what we're seeing into a better context. So yeah, it's really important. Following up on some of the UCMR3 thing, I guess I'm a little bit on the same side as David. I don't draw complete comfort from the numbers on UCMR3 and it's because of that Bemidji site that I just mentioned. We had done that statewide investigation of AFFF and we had identified that as a site where there was contamination and some even in the city wells. UCMR3, the first round did not find anything on that site and it's because it's an entry point sample that they're collecting. And so that city has seven wells and they happened to be pumping two wells that weren't contaminated and the first sample came back clean. The second sample came back, one of the really contaminated wells was being pumped and one, a clean well was not or was also being pumped at the same time. And so we had some modest levels that made us go back and revisit it. And now we've got drinking water advisories and they're looking to drill new wells because two of their wells are so contaminated and if they stop pumping those two all together, they'll just pull the plume up to the clean wells. And so UCMR3, it was really, as you said, Peter, it was a great start and a robust data set that really helped to bring this to the public's attention, but I don't think we should draw total comfort from the fact that only 1% or 2% of the wells or systems showed up as exceeding the drinking water numbers. For our, we have our own example of where it might not have caught it, just depending on which wells we're pumping at the time the samples were pulled. So. Right. And if I can maybe just add a little bit to my comment, it's not so much a matter of whether we draw a comfort and I appreciate, David, your perspective on if you look at a population number, maybe you think about that a little bit differently. It's not so much a matter of whether we draw a comfort from that or conclude based on those results, well, this just isn't an issue on the national level, but it does point to almost the juxtaposition between the public health crisis that seems to be occurring at the local level in some communities and then having a relatively low occurrence nationally, just it raises the important question that the administrator has to work through here of if the Safe Drinking Water Act refers to in terms of development of a maximum contaminant level, the language is in the sole judgment of the administrator, is there a meaningful opportunity to reduce public health risks through a national primary drinking water regulation? So if you tell all of the nations drinking water systems 50,000 plus that they have to sample for something that's found in a very small percentage, I think there are important questions. I'm not trying to point to direction one way or the other, but there are important questions that need to be asked. What are the tools that are gonna be most effective in addressing this problem? May well be that an MCL is the answer, but perhaps not. So thank you. I'm gonna take the opportunity I have as chair to get in a last comment slash question. I'm an environmental economist and so I've been very struck by the talk including this conversation you were just having by both Maureen and Peter particularly with concerns about costs. That certainly is very appropriate. There are those funds could be used elsewhere for health education and so on. However, it's also the case that Americans value very much their health and well-being. EPA Science Advisory Board has done a number of reviews of the value of statistical life and risk reduction of which I've been a member. And we know that people, citizens of this country value very much reduced risk of cancer, mortality, morbidity and so on. So it always strikes me as important if there are six million people that have already been, their drinking water is already being impacted, a back of the envelope cost benefit analysis would suggest to me that this is something very serious to much more seriously investigate and sample to get a better understanding of what the trade-offs actually are and any thoughts or reactions to a statement like that? Well, one of the processes that EPA is in the midst of right now is the UCMR is one of the requirements under the Safe Drinking Water Act that provides a very robust, your situation aside of in general a very robust data set to consider the frequency of occurrence of a contaminant in the nation's drinking water systems. The next part of this process is what we call the regulatory determination where the agency has the opportunity to make a preliminary and then final finding about whether they plan to regulate a contaminant in drinking water. And I would say that that process, that deliberation is underway within EPA right now. I just want to say, I'm not saying that this is a cost benefit analysis decision so we're going to spend the money. My concern is having the, not having regret that we have confidence that what we're doing is the right thing that we fully understand. These are in fact the risks that are associated with it. It's not just panic on the part of folks that, oh, you must do something now even though we don't have all the science, you know, I would want to have confidence that the numbers that are coming out from regardless what whether it's EPA, the state, ATSDR that there's confidence that those in fact are the right numbers and those are what we should be addressing. So that when we make this investment and address the risk that we are getting to the true problem. Excellent, thank you very much. That was just an outstanding panel. We couldn't have had a better group. I'd like to take a moment for everybody to give a round of applause for that really remarkable set of comment discussions. So with that, let me welcome David Sedlock to take things over. Great, thanks. I'm going to stand up here so you don't have to cook your neck over sideways. So at the university, one of the worst classes to have is the class right after lunch because everyone's got kind of low blood sugar and you got to rally the troops a little bit. But I guess I consider myself a little bit fortunate here in that you've seen some very nice overviews and examples. So I don't have to go into a lot of the details that I might if I were giving this talk to Nobo to a group that hadn't already been thinking about the PFAS treatment challenge. And so that's kind of good. And so I structured this talk anticipating a little bit what we were going to hear this morning and keeping it at a high level because I can't test you on the chemistry and engineering afterwards. So I thought it'd be more relevant that way. And so I'm going to start with my conclusions or take home points. And then I'll tell you how I got there. It's like a National Academies report, right? Everyone only reads the executive summary and they just trust that all the other stuff in there supports it. So if you need to check your email, pay attention to the first five minutes and then the rest you can just check your email. So the first thing we heard this morning is that it's not just PFAS and PFOA. I mean, you may be required Marine by Congress to only think about PFAS or PFOA, but you saw that this is a very broad family of compounds and we're learning about their toxicological properties. And so I think it's important to recognize that we're going to have to address this broad suite of compounds. And I think the take home point is that characterization and comprehensive characterization of sites before remediation is essential. And so I think it's a missed opportunity to go and spend $200 million characterizing sites and only measuring two compounds when you know there are more compounds there. And so I'll give you some guidance on ways in which you don't have to become a cutting edge analytical chemist to get Garner information about full site characterization that will be useful in making sensible decisions later. The second point is it's not just military sites. I mean, we heard from Marine that PN from Rula that the PFAS compounds are A-Triple-F is a very small fraction of the PFAS production and use in the world. And I think the implication here is that CERNIP and ESTCP and Andrea will tell you some great things that they've been doing has been doing a lot of good research and development, trying to understand issues related to managing these compounds and remediating them. And if you're fortunate enough to have contamination issues that look just like the Department of Defense, that's great, they've done your work for you. But there are a lot of sectors of society where the contamination issues look quite different than those that CERNIP ESTCP is dealing with or Department of Defense is dealing with. And those groups have not been doing their homework and need to do some research and development to get a handle on this problem. And it's not currently being done. The third thing is, and I think you already seen this, it's not gonna be easy. And we've heard a little bit about the remediation. I think if you remember anything from this morning about remediation, is that we're back in the era of pump and treat with activated carbon adsorption. We know that that's a hard road to go on. And what that's gonna mean is that many times in the near future, our remedial options are gonna be less than optimal. We're gonna have to think about things like leaving contaminants in place and trying to prevent them from moving any further. And those come with risks and liabilities. And we're gonna have to have some forthright discussions about them. And as we heard this morning, and I think Ginny kind of gave me nightmares with that Mississippi River plume thing moving, is that the lessons we learned from solvents and all the remediation we've done the last 30 years don't necessarily apply to this family of compounds. And so I would wanna be very careful before I advocated for one of those suboptimal solutions. And finally, it's really important that we avoid introducing new contamination. And I don't think we've talked enough this morning about the role of source control. But I think you can make a mistake once, but if you keep living that mistake over and over, it's a bit of a problem. And I think that there's enough evidence out there that we need to be thinking about green chemistry. We need to be thinking about ways to avoid exacerbating problems by introducing new problems to the system. And I think that that's clearly seen in some of the piecemeal efforts that were done earlier on on AFFF. And I think that that should be part of this broader discussion. And it hasn't really been talked about yet today. So that's what I wanna talk about is my take home points. And hopefully that I'll take 25 minutes. Okay. Let's talk about comprehensive site characterization. I think you've already seen this slide already this morning, but this universe of PFAS compounds is broad. It's more than just PFOS and PFOA. So we have the perfluoroalkyl substances and the polyfluoroalkyl substances. And I think the key here is that the polyfluoroalkyl substances contain these things that we now refer to as precursors. And the reason we call them precursors is that in the environment and in treatment systems and during remediation, they can be converted into the PFCAs and PFSAs. So these recalcitrant perfluoroalkyl substances sometimes are directly released to the environment. And sometimes their precursors are released to the environment. And then those precursors, which may be toxic in their own right, they may undergo in vivo metabolism and get converted to these things in the body or they may get converted to these things in the environment. And so just going out and measuring the perfluorocarboxylic acids or the perfluorosophonic acids is not enough because these things may increase in concentration over time. And I'll show you some data on that in a moment. So this is what I mean by polyfluorinated compounds getting converted into the acting as precursors. This compound here, 6-2-F-T-A-O-S, this is one of those polyfluorinated substance, alkyl substances in A-T-F-F. In fact, this is one of the major ones I think this is from not from 3M, but the other family of A-T-F-F compounds. And you can see its structure here. You have this perfluoralkyl group here. Here's the C8 version, the C6 and the C4 version. And we found in our research that in the presence of aerobic microorganisms, they undergo a sequential transformation and the terminal products of this biotransformation process is the perfluorocarboxylic acid. So you start out here with a six-carbon chain and at the end, all you're left with is that six-carbon chain with carboxylic acid at the end. And so these are the compounds that are present in A-T-F-F. In fact, if I took a sample of A-T-F-F and tried to measure the concentration of the perfluorocarboxylic acids, I would get very low levels, very small fraction of it. But if I took that same A-T-F-F and exposed it to aerobic bacteria, I would get very high concentrations of the perfluorocarboxylic acids. That's what we mean by a precursor. We've seen this now on aerobic biotransformation. We've also published a paper recently on anaerobic biotransformation. So we're pretty convinced that these things break down in the environment. And the thing you're probably asking yourself is, wait a minute, I just saw a bunch of talks this morning where people are wondering how we go from measuring only two compounds to measuring four and six and eight and Ginny told you about how long it took their labs to get certified to do all these analyses. Well, don't worry, there's a simple way to do this. So we developed an analytical method back in 2012 called the PFCA precursor analysis or as my colleague Jennifer Field likes to call it, the top assay, total oxidizable precursors. And we designed this assay such that any commercial lab that was capable of measuring the perfluorocarboxylic acids could measure all of those crazy precursors I showed you in the previous slide. And the way in which we do it is we take the sample, it could have a nitrogen group here, it could have one of these alkyl groups here that makes it a telomere. And we take it and we expose it to hydroxyl radical. Maybe if you're familiar with advanced oxidation processes used in drinking water, hydroxyl radical is the workhorse of that method. The way in which we make hydroxyl radical is we put some sodium potassium persulfate into the sample, we put it in a plastic container, we screw on the top and we put it in a warm water bath. So any analytical laboratory that has a warm water bath and plastic bottles can drive those precursors to their corresponding carboxylic acids. And what you measure is the increase in concentration from the original sample to the sample after it's been treated with the hydroxyl radical. And that is a simple way of measuring these precursors. Now, my colleagues who have fancy analytical equipment love to develop all kinds of compound specific analysis and there are a lot of reasons why environmental chemists need that information. But for understanding and performing a comprehensive site characterization, this total oxidizable precursor method is all you need to do. And we're seeing it being commercialized by commercial labs in the US and Europe and Australia. So I get emails from commercial labs saying, hey, we invested a bunch of money in taking this scientific paper that you published in 2012 and turning it into a method that our customers can use. So now we're at the point where it's commercially available, it may take years for EPA to get it certified and run through, but I think anyone who's serious about doing a comprehensive site characterization would be remiss in not trying to measure these precursors. And the reason I do is that when we go out to actual sites, so these are data from the Wurtsmith site, one of the A-triple-F contaminated sites where there's a firefighter training area. And what I'm showing you here is the fraction of the PFAS compounds that were measured either as the sulfonates. So this is like PFAS and it's sisters. And then the carboxylates, that's the black line here. And these are the precursors, the things that you don't see unless you expose the sample to hydroxyl radical. If you take the ancillate triple-F and you measure it, you don't see any PFAS, you don't see any PFOA, you don't see the carboxylates or sulfonates because it's all precursors pretty much. And if you take the 3M formulation, you measure lots of the sulfonates depending upon what era it's from, it's either a C6 or C8 sulfonate, and you see about a 40% precursor. But when those go out in the environment, in soils or aquifer solids or groundwater, you see the precursors growing in concentration over time or in fraction over time. So what happens is the original firefighting foams have this signature. When it goes out in the environment, you see the concentrations of the perfluorocarboxylates growing over time. And you see the precursors shrinking over time. And we have seen some unidentified precursors as well. But the idea here is that if you wanna do a full site characterization, it's pretty easy to learn about these precursors using the total oxidizable precursor assay. And when we go out in the environment, we often see high concentrations of those precursors. And at this particular site, the firefighting activities had stopped about 20 years before we collected these samples. So the precursors are quite persistent in the environment, even after remediation and all kinds of things, they're still there. So the second thing I wanted to kind of get through to you is that different sources of PFAS are different kinds of remediation challenges. So most DOD sites are dealing with AFFF, mostly a firefighter training areas, some of them at crash sites, some at storage areas. But this applies not only to the Department of Defense, it applies to civilian aviation, as we heard from Marula's talking, and it applies at refinery. So if you're from FAA and dealing with civilian aviation, if you're a refinery and you used AFFF, you should just be paying attention to SIRTEP and ESTCP and let them do the heavy lifting and R&D for you. But let's talk about some other industries, let's talk about industrial sources. So I think we all know about Husik Falls now, we know about Little Hawking, we're learning about what's going on in Michigan with the leather treating, we're learning about these chromium plating facilities. AFFF research doesn't necessarily apply to these sites because the mode in which it was introduced to the environment, the co-contaminants and the specific fluorine chemistry, PFAS chemistry is different. And so SIRTEP ESTCP is not gonna do research on Gen X because it's not in AFFF. And so we need to be doing more research and development that's relevant for industrial sources. Polymers and coatings, we've heard a couple times already about the presence of these compounds in landfill lead shape. There's research that was published by EPA, John Washington, I think was in Georgia at the time at the Athens lab, showed that the polymers slowly release PFAS compounds over time as they degrade. And when we talk about these compounds, the carbon-fluorine bond as Rula pointed out is incredibly strong. Some people refer to them as the forever chemicals. Well, forever is a long time. And if they're breaking down at the rate of a few percent per decade, a landfill is gonna be there for hundreds of years. And so they're gonna be in the landfill lead shape. And so we're not doing enough R and D to understand that. And then this issue of contaminated organic material, biosolids, compost, it's come up over and over around the world now. And that's not something that you're gonna learn from the DOD's efforts. And we need to understand this pathway more. So let me give you a couple of examples. So here's Gen X. This is a paper that came out in 2016 from a group from North Carolina State University. This is the group that discovered the Gen X in the river downstream of the fluorochemical manufacturer. And you can see that the concentration of the Gen X was much higher than what they refer to as the legacy PFASs. That's the things we've been talking about this morning. And this statement strikes me as quite interesting. So it's chemors, right? DuPont spun off the part of the business that had a triple F in it and some of their other fluorine chemistry as chemors. So although the chemor's plant is west of the Cape Fear River, that's right here, test detected HF-PODA, one of these kind of Gen X-like chemicals in private well water at residences east of the waterway. So somehow it got onto this side of the surface water. A small lake several kilometers upstream from the chemor's plant and about a kilometer from the river had 915 parts per trillion. DEQ reported in November. And a separate recreational lake several kilometers from the plant in a different direction, so 620 parts per trillion. We still don't know exactly what's going on. It's possible that that factory took some of their waste material and sent it to other places. It wouldn't be the first time that that's happened that you had unclassified materials going to dump sites or you had things. Like I've heard stories about firefighters in Australia who got a triple F on their uniforms and they took it back to the laundry at the fire station and it got washed in the fire station and it came out in the landscaping water from the gray water reuse and contaminated the aquifer. So it's possible that just strange things happened around the factory or there could be like a diffuse source of this. It could be deposited from the atmosphere. And so it's quite possible that the cleanup of this fluorochemical manufacturer might actually involve a much larger area of diffuse low concentrations, possibly surfacial soil contamination and groundwater contamination. You can't remediate miles and this is the factory, right? You can't remediate miles and miles around this factory but if you don't do something, it's going to continue to leach indicate fear and into the drinking water supply for many, many decades. Because as we've seen these things get these long plumes and we saw from Ginny's talk that there's a lot of communication between surface and groundwater. And so it might be many, many decades that this river that's a water supply for people downstream has high concentrations of these compounds. That's a different kind of remediation contamination than a firefighter training area. Here's another example of something that I think we're not worrying enough about and that's contaminated organic material. So back in 2006, in Zauerland, in Germany, this is Northern Germany. I can say that because I speak German sometimes. It's enough beer we all do, right? They had a PFAS contamination incident. And what happened here was that there was PFAS contaminated soil amendment like a compost material was applied by farmers to their fields and it got into the river and went downstream and contaminated the reservoir and that reservoir was a drinking water supply of 40,000 people, 2006, 12 years ago. So these things have been going on for a long time and you can look and see not only biosolids but also sometimes you'll see that different types of soil amendments and organic material get contaminated, get applied to the land and run off. Now back in the days when we used to worry about PCB contaminated sewage sludge, that didn't happen. If you applied PCB contaminated sewage sludge to a farm, it kind of stayed there on the farm on the soil. It didn't contaminate the downstream drinking water reservoir and so you didn't see so many people's water supply being taken out of action. I can think of very few examples where the old cast of characters, the PCBs, the TCEs, the PCEs knocked out water supplies for 40 or 50,000 people by contaminating a reservoir and this was a relatively small incident of a soil compost amendment that was contaminated. Now let's talk about the remediation challenge. This is the NRC, the National Academies Report. There's copies there in the back that I think Stephanie is trying to get out of her office or something because they're taking up too much space. But it's a wonderful report and it's about this alternatives for managing the nation's complex contaminated groundwater. And again, if you read the executive summary, which is all I read, I trust Mike Kavanaugh, he did a good job and the committee was great. You know, there are many complex sites that still remain. So here we are at 30 odd years after Superfund and there's still a lot of sites that we don't know how to fully remediate and part of the problem is that we've learned that the pump and treat solution to groundwater contamination is problematic. It takes many, many decades. We don't always understand the hydrogeology perfectly. And so in some ways it's throwing money after a problem and not necessarily solving it. But the other treatment technologies are quite limited. We know something about bioremediation. We kind of are starting to understand in situ chemical oxidation, but these are all kind of technologies that need like a little bit more development before each one isn't a little miniature PhD thesis. And then this issue of leaving contamination in place, it's a suboptimal outcome. I mean, oftentimes on complex sites, the decision is to manage it and make sure that people don't get exposed to it over time. So you cap it, you put a slurry wall around it, you have hydraulic isolation. And those are problematic, especially from a legal standpoint because it's hard to walk away from the land because you have continuing liability. So it often drives us to some of these more expensive remediation issues. Well, here's plumes from the Ellsworth Air Force Base that we studied back in 2014. And those plumes, we saw them from Ginny's talk, so I'm not gonna belabor the point. They look a lot like those plumes that we couldn't quite fix with pump and treat before. So right now our main option is pump activated carbon and burn the carbon or get rid of the carbon somehow. And these long plumes with this stuff that sticks to the groundwater sediments, this precursor issue, I really don't think pump and treat is a very good investment of money to solve these problems, but we really don't have too much else in our arsenal. And so we've been trying to develop an in situ remediation technique and this grew out of our work on that total oxidizable precursor assay. What we learned in that is that if we use persulfate, which is what we use in the total oxidizable precursor method, if we use it on these compounds, we can convert the precursors into the carboxylic acids. So here's an example with, I think this is with the Ancel A-triple-F. We can expose it to sulfate radical, which is what we produce when we heat the persulfate and convert it into the carboxylic acids and then it stops. So we get it to the carboxylic acid and then if we do the same treatment at a pH below three, we can take the carboxylic acids and mineralize them, turn them into carbon dioxide, water and fluoride. So this is pretty much the only treatment technology that I know at this point that has potential for breaking down PFAS compounds in in situ chemical oxidation methods. The problem with it is you have to get the groundwater or the aquifer sediment pH down below three and that's something that, yeah, it takes a crazy person, but Rula and I have a project that ESTCP funded. So I guess Insanity Loves Company, it's actually an aquifer that's pretty sandy and has very little calcite. And so it's pretty easy to drop the pH below three. In fact, as soon as you add the persulfate, the pH drops below three because the persulfate when it reacts, it forms sulfuric acid. And then at the end you adjust the pH back up, but we're able to mineralize these things. The only problem is it doesn't work on the sulfonic acids. So anytime someone used a 3M, A triple F, sorry, we can't help you there. And it's not easy. I mean, it's still a kind of a method in development, but all the other stuff you might hear people talking about magic in situ treatment methods, none of them are borne out. It's all been a lot of weak science as far as I've seen so far. So this is the only one I know of that has potential to break down these compounds in situ. And so this is what we're doing on our ESTCP project with the Navy. Basically, we first add hydrogen peroxide to the groundwater and that as a hydrogen peroxide breaks down, it generates heat and the heat is necessary because then we add persulfate and at the high temperatures, the persulfate breaks down to form sulfate radical and drops the pH. That mineralizes these compounds. Then we have to neutralize the groundwater and start over again. And so if we have the sulfonates there, then we have to follow this with XC2GAC. So this is not a great solution, but it's about the only one we have and we're hoping to try this in the coming year at a Navy site. But if that doesn't work, all we're stuck with are these suboptimal solutions. So currently the main suboptimal solution is you excavate the source zone and you treat that material thermally. That's probably the best way to deal with the source zone itself and then with the groundwater, it's back to pump and treat and pump and treat and pump and treat. And the main way in which people are dealing with pump and treat is they're adsorbing an activated carbon and then they burn the activated carbon to make sure these things break down. There is work going on ion exchange resins and all kinds of like proprietary materials for zorbing it and allowing you to recover that material in a smaller volume, but it's all pretty much, you know, has to compete with activated carbon, which is a proven technology and relatively, is going to be inexpensive relative to these other options or destruction. So SIRDEP has invested in developing electrochemical treatment methods and photochemical treatment methods and those are fine, they're an alternative to GAC, but again, the key here is that you have to pump this stuff out and you have to be very patient as it slowly comes out of the aquifer. Another suboptimal option is confinement. So there are companies that make different types of materials like proprietary materials, usually made out of activated carbon or some other material and you mix it in with the soil and then that absorbs the PFAS compounds and decreases their mobility by tying them up in the soil and maybe you couple this with capping the site to prevent the water from getting in there and leaching it away and maybe you hydraulically isolate the site by pumping, but clearly that's also not an optimal solution because it's a long-term management challenge. You have the potential that these things will expose people later. If you think about what we did with all that PCB contaminated sediments in the Hudson River, that was that idea of digging it out and putting it in a place and capping it, but there we also have the reductive dehalogenation working with us and so we knew that over time, those PCBs would eventually become less toxic. These PFAS compounds are gonna be there forever if we choose this option and so short of making this into cement, it kind of starts sounding like like a nuclear waste disposal issue. You have to have some sort of good stewardship program and lawyers don't like that. They don't like transferring land if there's still a continuous liability. The other suboptimal treatment is treating the drinking water supply and so you can certainly have well-head treatment or point of use treatment as we saw earlier today. Obviously those are challenges. I mean, we talked about this with the arsenic challenge in drinking water 20 years ago. They're not the greatest way to go and it also ignores the fact that we have surface water contamination and eco risk. So we can't ignore the fact that these things get out in the environment and they pose risks to endangered species, to marine mammals, to fish and people who eat fish. So it's not a great idea. And again, the groundwater, we can do well-head treatment with activated carbon usually or reverse osmosis, for example. Under the sink, you can put a reverse osmosis system in someone's house and that keeps these things out but these are kind of expensive ways to go. If you have a whole river that's contaminated like in North Carolina, yeah, you might have activated carbon at the drinking water treatment plant but some of these compounds have a very low affinity for activated carbon, which means that you burn through your activated carbon very quickly. So again, another suboptimal option. I think that we also need to have a discussion about product substitution. I don't think, I think that we have to think long-term. We might have a legacy of things that we did before we knew any better. We might have some things that contaminated the groundwater after we should have known better and maybe the lawyers will spend a lot of time recovering money to clean that up but going forward, it's on us. And I think I'm already seeing some recognition of this. So for example, this is not an advertisement. I don't get underwritten for what I say. These dates here are the dates where these clothing manufacturers agreed to take perfluorochemicals out of their clothing. Do you notice the stain on my shirt? No, I didn't think you could. I had the stain on this shirt. I had to buy this shirt in an airport in Germany when Lupetanzer lost my bags. And so it's from Germany and it doesn't have any PFAS in it. And when I got some food on it, it caused the stain but you don't notice it, so I don't care. So I guess, I don't know what Peter was saying about the indispensable chemicals. But the Green Science Policy Institute in Berkeley has been doing a great job talking to manufacturers. Just a few weeks ago, they met with the carpeting manufacturers and explained this issue to them. The carpeting manufacturer said, oh, we have a stain-resistant requirements in our carpeting and when they understood the issue and they understood how consumers felt about it, they said, ah, maybe we don't need it. Maybe wool carpets are fine or maybe the other types of stain-repellent materials we have are fine. You know, the AFFF and the Air Force and DOD, they are finding, see, the Navy is doing research on new types of firefighting foams and ways of changing the military spec to allow for the use of non-floring-containing foams and that's happening overseas and it's happening in the States and I think it's something we should be talking about more. So yes, there probably are applications. I'm a lab person. I love my teflon. I love my napheon. I don't wanna get rid of it but we need to have discussions about which applications of these wonderful chemicals are necessary and which ones the convenience is not enough to justify the environmental contamination. Okay, so a summary of what I told you here. Absolutely positively, comprehensive site characterization is possible. You don't have to be at the cutting edge of analytical chemistry to do it and it needs to be done. It'll just be regrettable to spend money on site characterization without doing it right. Remedial options are still quite limited and still quite expensive. DOD has done a wonderful job trying to understand and develop new technologies. Everyone else has done essentially nothing and could do a lot more and then in terms of preventing these things in the future up until now, it's all been voluntary action. I don't know. I know that it's politically easy to rely upon voluntary action for all of your solutions but there comes a time when the country is spending too much money and the health burden is too high for products that are not essential. We're not talking about lifesaving drugs here where there should be a discussion about which ones we should be manufacturing and releasing to the environment and that I just wanna end by acknowledging support that we've had from the UC Berkeley Superfund Research Center which is funded by NIEHS. Thank you very much, Chris. And then ESTCP and CERDA, thanks Andrea. And also friends, my colleague, Lisa Alvarez-Cohen at Berkeley, Rula, who's worked with us on a lot of these projects. And you see Jennifer Field and Chris Hagan's name coming up over and over again and that's because they've really led us in a lot of these areas. Thank you for your attention. That's outstanding. I think we'll go ahead straight away to Andrea and then, and take questions afterwards just to be sure we get everything out there. Do you wanna do a different point? No, it's all right. It's all ashamed with advertising. Should I take the... You want this? Yeah. Okay, you can hear me okay through the mic. All right, thanks. I'm Andrea Leeson from CERDA and ESTCP and what I wanted to do today was really try to show you the breadth of essentially the heavy lifting we've been doing, which means I can't dive into tremendous detail about any one project, but what I hope to do is show you what we're doing, where you can get more information if you want it on specific projects and maybe it would also show you where some of the gaps still exist that we haven't been funding. Before I jump into that, let me talk about who we are for those of you who don't know us, we're sister programs. CERDA is our science and technology program. It's a strategic environmental research and development program. This is operated in partnership with the EPA and the DOE. And it's your basic, it's a little more basic to applied research perhaps. Often it's conducted at universities, sometimes research branches of consulting firms, research labs in the military services, but primarily it's at that research university level. We are very closely connected with ESTCP, which is our demonstration validation program. This is a DOD program and this is to take the technologies or the knowledge that's developed out of CERDA and can be matured and demonstrated under ESTCP. So in ESTCP, we're going to the field, we're testing out the technologies at real sites and trying to get cost and performance data to see how those technologies work. The two programs are so enmeshed with each other that it's all jointly managed by the same people just quickly too. So what we have a number of different drivers, but where PFAS comes in is this issue of course with the contamination from past practices and we try to stay ahead of this to keep an eye on what kind of emerging contaminants we have to be aware of, where we need to put our research with a focus on DOD unique or unique chemicals or those that are a big challenge for us. So we have a number of different program areas. Now, I run the environmental restoration program area. So the vast majority of the work we've done on PFAS is in my program area. We have a little bit, I like to just point with my hands, I don't know how to do that. We have a little bit under one of our program areas that is, it's called weapons systems and platforms. It's kind of like your traditional pollution prevention where we're looking at chlorine free replacements for AFFF. So we've got a little bit of that work going on, but I wasn't going to go into it because it's not under environmental restoration. And those projects are getting going, I think they were a 16, 17 new start, which means they haven't gotten very far yet. We have contracting process and it takes forever. But this graph is to give you the big overview of everything we're funding right now. And what this shows is on the top half here, you have the work that we're doing under SIRDUP. So again, mostly the research, each of these boxes represents one topic area that we released a solicitation on in the corresponding to the fiscal year in which it was released. So these are topic areas and that means we've funded several projects under each one of those. The bottom half is ESTCP and these are very specific projects, not topic areas that we're funding. So what I wanna do is walk you through this a little bit and what we've done. So we started in 2011 with a statement of need on in-situ remediation. And we released this shortly after the EPA released their provisional health advisory. So they did that early in the year and that same year we came out with this topic area. And we were like, okay, let's just do in-situ remediation. So we did that topic area. We ended up funding three different projects. They weren't, they didn't have as heavy a focus on in-situ remediation as we expected. The one that was strictly remediation was not actually successful. It was a one-year proof of concepts. We weren't able to continue it. And the other two that you probably heard a lot about already was Jennifer Field and she was looking more at fate and transport and Chris Higgins, sorry, I got those flips. Jennifer was doing fate and transport delineation of the fluorochemicals that are out there. And then Chris was doing more of the fate and transport under different conditions. Jennifer's project actually ended up getting the project of the year under SIRDEP this past year. I think her project was really the foundation for much of the work we funded after this. And a lot of it was giving us a better understanding of the different compounds, identifying the precursors so that we know what we're dealing with with the projects that we're looking at. So we followed this up in 2014 with another solicitation on in-situ remediation and we're like, okay, that first one we didn't really get very far with actually developing technology. So let's try this again. It's still an issue. We know a little bit more now. And so we ended up funding five projects under this statement of need. Where it says C, that means that's our acronym for a proof of concept project. It's generally one year, a couple hundred K. And if they're successful, we will follow on. What I should also say is at the end of this presentation I'm giving you a link to our website but every single project we fund you can find it on our website. It gives a summary of the project. It gives the name and contact information of the lead investigator. And once there are reports, all the reports are posted there so you can get everything you want from our website. We funded these five different technologies. We had one that was not successful fairly early on. We realized that this was our proof of concept actually struggled a bit there. We ended up with an adding on another year to try to see if we could get the degradation we're interested in. And the last three down here they're looking at different technologies. They're finishing up the most promising one so far has been the sorption technology but we don't have the final results yet so we're kind of still looking at that. Around this time we started our ESTCP effort. In 2015, much of what Jennifer had done under her started project we built into a technology transfer product to get that information out there. Very specifically to get information about sampling and analyzing these chemicals out to the vendors who are doing this work because that was also a big issue for us. We don't have really standardized methods for analyzing these many different compounds and we don't have them for sampling. We also started a project in 16 that was more to go out into our field sites to better understand some of the characterization and extent of the contamination at various sites really just building our database so that we got a better understanding of the site. And then we've got three new ish projects that are looking at different treatment technologies. All of this is very new and David was able to give you some of the most up to date information about those co-PI on one of those projects. I wanna talk a little bit about what we're doing on eco toxicity. We had a workshop on this issue back last year and what we do at our strategic workshops as we get together in this case probably around 60, 70 people experts in the field either with a mix of people who are either conducting research on these issues at university, they're either applying it in the field or they're an end user. And by that I mean it could be a regulator who has to deal with these sites, someone who has to manage the sites in different military branches. We get them all together to talk for two days, brainstorm about these issues and then come up with a plan or not so much a plan but a list of our data gaps. Here's what we don't know and we use that directly to plan out what we need to fund over the next five years or so in these areas. So one of the issues that came out of that was the whole eco toxicity issue. We do not fund human health risk assessment. There's a lot of agencies that have a lot more money than us to do that so we've never done it but we will do eco toxicity. We do mammalian work. We need that for our eco talks work at our bases but certainly of course mammalian work can be used to inform your health studies, human health. In the eco talks we funded four different projects and they were very specifically to fund data gaps that existed that we were aware of. So they are very specific. We have an avian project, amphibian, reptiles, mammalian, fish and vertebrates and they're all kind of taken a piece of that. They are just now starting to come out with some results about the eco toxicity of some of these compounds and I'll just say they are not looking at just PFOS, PFOA, they're looking at a whole suite of compounds so that we have a better understanding of which of these constituents we need to be concerned about in terms of toxicity and the results are new enough. I'm not going to repeat them, they're not published yet and I would say they're still preliminary but again, you can't go to our website and find all those projects and the lead investigators of them. One thing we were also doing is that what came out of the workshop, there's a lot of kind of miscellaneous data gaps that didn't fall under any one area so we did kind of say, we need some basic information and one of these was in developing the spaces for an approach to assessing PFAS risk to threaten an endangered species. So we've got a number of projects there just getting started this year so we'll have a lot of information on this within check back in 18 months or so. We also followed up with a full statement of need or topic area on the ecological risk characterization of PFAS is in the subsurface. We have these ecotox projects that we funded that started in 2016 but there was still quite a bit that came out of the workshop that we felt still hadn't been addressed. So with FY19 that means we have these proposals in-house they're just now finishing up peer review and we'll be making selections on those in July for funding later in this calendar year. One other item we've looked at we had several years ago we had a long-term management workshop which is more on groundwater issues holistically and the issue that kept coming out of there with the whole issue of the mixed contamination these chemicals generally don't exist alone by themselves in an aquifer. We have used them at our firefighting sites which generally means chlorinated solvents maybe one for dioxin is there. So we often have a mix of contaminants. A lot of our sites are already undergoing remediation and we don't necessarily have a good understanding what's happening to these the PFASs undergoing the remediation options we've already gotten place. So we funded five different projects to look at the mixed contamination issues. Most of them are with chlorinated solvents and the PFASs, these are all 2017 new starts and just getting started. I already mentioned how we had these workshops and I just wanted to summarize that the workshop summary report I think is still current still has a lot of valid information in it it's only, that's actually only a year old now we had it one year ago this month and basically what we're doing is we give introductory presentations on the state of the science as we know it issues associated with our end user community at our bases and then we turn everyone loose to come up with these needs and we identified 28 different data gaps associated either with research demonstration or technology transfer. That is one of my biggest issues technology transfer is how do we get the information that we've developed in the lab or in the field and get it into the, put it in an understandable format for actionable work for people who have to use it so that is one of the needs that we address is what need to be done with tech transfer. Major findings and these are all gaps we still identified state and transport, bioavailability, biomagnification, toxicity still had a lot to do with different development of different technologies, lot of interest in PFAS forensics and then the sampling and analysis needs. So one of the statement of needs we released was on the source phones of PFAS I know we've had a little bit of talk about that and we felt that we really in order to better understand our plumes, we needed to better understand what was going on with the source phones and what we needed to do there. So we did fund several projects there and I thought they represented a really nice mix of looking at the beta zone, saturated phase, developing predictive pools, air water interface and then one on field sampling and assessments. I thought we got a great suite there. Those are not on contract yet but hopefully they will be soon and they'll get started and then the last thing I wanted to go through with all these different treatment projects that we're funding, we have a lot and I think I'm even missing a couple on here but just generally what you can classify and we have a couple of one that are focusing on destruction technologies. This is our new sort of work and doesn't even include what we're doing under ESTCP. We have several more that are focusing more on sequestration mechanisms and the projects that are up here, these are full projects, three or four year projects. Here, these are proof of concept and you can see we have quite a few proof of concept and I think that just illustrates how difficult this issue is and then at the bottom that's even more proof of concept. We have a number that are looking at treatment train approaches with which I think is going to be the way we have to go with often a more aggressive technology to try to break apart some of these compounds followed by something a little less aggressive, more passive. We have the three projects looking at the mixed contamination and then we have a whole slew of projects, these new proof of concept that looking at investigation derived waste. That is a huge issue for some of our bases that as they're doing these characterization plans they end up with the investigation derived waste, the soil cuttings, the groundwater itself and it's expensive to have to deal with it. So hopefully we'll be able to develop something here to help with that issue. So to date, we have either spent or have committed to spend with projects that are already on contract roughly about $40 million. A little over 5 million of that is associated with ecotoxicity. This does not include any of the new projects that we'll have going in FY19, which is quite a bit. We have two new statements of need on sampling and analysis as well as bioavailability and biomagnification. What we've certainly seen to date is that we need additional research and demonstrations in all the remediation areas, in-situ groundwater and soil treatments but ex-situ is important too because we have a number of bases that are having to treat these contaminants in their ex-situ systems and they're struggling. They don't have the funds to do it. It's a lot more expensive than what they've been having to do and we do need those options. I'm optimistic. I think we have good progress on several fronts. It's a huge amount of work that we've got going on. I think the technology information, we need that to inform our remediation so that we understand which chemicals we need to be most concerned with. In terms of resources, this map that I've been showing is online. It's on our site. If you go to startup-estcp.org, I have the link there. Under our featured initiatives, you'll see this PFAS page. And if you go to this map, each of these boxes is dynamic and if you click it, it'll take you to a summary of the topic that we released and it'll give you a list of all the projects that we selected and from there, it'll give you links to the project pages so that you can take a look at that. I think the workshop report is still useful, still valid, there's a lot. We've tried to put out solicitations for as much as that as we can to try to fund those data gaps. We haven't covered everything yet and so I think it's important to keep an eye on that. And then we have a nice FAQ that came out from the technology transfer project I talked to you about and that's also online now with I think the video that goes with it is also online now. I wanted to also mention what we've done. You can see it's a vast number of projects we've got and I'm one person. So we do now have a working group, a number of people are assisting us with the PFAS work to kind of review what's going on and the big thing there is I think it's important that the right people are talking to other people. The researchers are coordinating, they're collaborating when it makes sense. We are in the process where we're going to have everyone working on the same groundwater and soils from the same sites so there's some consistency there. So we'll be working on them with that. And at the upcoming symposium, we have a third epine-STCP symposium every year last week in November. We'll have a day of PFAS where we'll have more formal technical presentations in the morning and then a brain, that's not a brainstorming session but all of the investigators gonna get together to have time to talk more informally and directly with each other about what's going on. The afternoon is closed door but you know, you have it in, you can talk to me if you'd like to be there and see what's going on. And I think that's my last slide which was a lot of information but if anyone had any questions, be happy to answer them. All right, thank you, that was wonderful. We have a few minutes before we have a scheduled break. So I think questions to either of our panelists would be appropriate. Thank you, I was gonna ask this of you David but others may be able to talk about it as well. I'm sure they can. To just talk a little bit more about the transport properties in water, I mean, is it just so soluble and stable that it stays there? Is it sorbed onto particles? Oh, it's, they've been an interesting voyage of discovery because they're not like the contaminants that we studied the last 30 years. They're not, you can't just think in terms of optimal water partition coefficient and hydrophobicity but you also can't treat them like anions that undergo anion exchange reaction. So they're so-called oleophobic compounds. They sometimes absorb but not super strongly like dioxin or PCBs more like distribution coefficients that are more like some of the, I don't know, hydrocarbons that we're more familiar with. The precursors can be negatively charged. They can be positively charged or they can be positively and negatively charged to so-called zwitterion. So there's kind of, what you saw, I think the best example of why they're so challenging in terms of fate and transport was from Ginny's talk this morning. You saw that they do stick around near the original site of contamination. So we're not talking about like one for dioxin or perchlorate where it's gone but at the same time they move pretty far. So over a period of decades, you saw them migrate from the waste sites all the way to the Mississippi River and contaminate a bunch of things in between. So they're a little odd in a way that contributes to rule this perfect storm because they do stay in place near the site of contamination which means you have to go back and do source cleanup and source control but they also can move very far and leave a footprint everywhere that they went. And so I think that's what we see in a lot of these sites a relatively large area of contamination that will stick around for a long time. I don't know, others who've been working on them might have a different perspective. Just watching. Ginny. Well, a couple of things have occurred to us over time because we had assumed that the reason we still had this big footprint even though they're so soluble and mobile was that it was just matrix diffusion and the stuff getting trapped in the back roads of the aquifers and just slowly chemically diffusing out of them that all the work on the precursors which we weren't even aware of at the time makes me wonder now if we also don't just have ongoing because we weren't able to excavate all of the source material. Do we have ongoing generation and dispersion of the contaminants away from the waste site? Yes. Now the paper from the Ellsworth site that we did with Chris Higgins and Jennifer Fields showed that it looked like the precursors might stay in place and then when they get oxidized they might become more mobile. Right. And we even, I wish I'd known some of this while we were doing some of the work because we actually saw pulses, especially of carboxylates leaving the sites when they went back and did additional excavation. So they opened up these essentially anaerobic systems, the landfills and I'm assuming we introduced a lot of oxygen and the next thing you know we've got a huge pulse of carboxylates leaving the site. It would have been great to know that in advance and kind of one, anticipate it, warn people and then two, to have tracked it a little better to be able to talk more than just sort of arm waving about we think this is what we're seeing happen. So yeah, I don't know, follow up. One other thing I might add to that in terms of on the remediation side so we have a large carbon filtration system going in one of the cities Oakdale and the relative absorption rates has been really interesting to look at because PFBA is relatively difficult to absorb but the system is big enough to capture it at the beginning but it breaks through pretty quickly and by the time they get to their annual change out it's still absorbing the PFOA and PFOS but they outcompete the PFBA for absorption sites and they kick it off of the carbon. So our effluent is actually higher than our influence on that system and since it doesn't exceed the drinking water numbers, we don't worry about it too much but it's kind of a cautionary tale about having to engineer your systems if you're trying to treat from multiple PFAS. Well, I was just gonna ask Andrea if you could just elaborate a little bit on some of the experimental work focused on the transport issue and dealing with that or trying to reduce that. In terms of what they're doing. It's not on anymore? Okay. The most of the fate and transport work we did was with Chris Higgins at Colorado School of Mines and what he really was focused on was looking at how the compounds moved in the subsurface under different treatment scenarios and I know he was looking at in situ chemical oxidation how it went under there and bio remediation which is not, didn't see much work there but he did see it being somewhat affected by in situ chemical oxidation but I don't remember additional details. Now his project is complete so his full final report is on our website though if you wanted the details on that. Hey David, I had a question for you regarding the product substitution. So I was just curious whether some of the groups that you put up there the corporations that had voluntarily chosen to phase out their use are they using replacements and if so, I mean, because Gen X was a replacement for PFOA and so there is some worry about if the replacements are suitable so are they just choosing to eliminate the need or what's going on there? The work that I talked to you can visit the Green Chemistry Institute website. It is all about avoiding regrettable substitutions and so I think that was the point I was trying to make is that when you have a C8 compound and you say, oh the C8's not good, we'll replace it with C6, that'll solve the problem. I think we've seen enough cases of regrettable substitutions with brominated flame retardants and refrigerants and now for fluorochemicals that people are looking at different chemistries that can still achieve the same things that consumers want but without the environmental risk. So it's a great point that whenever we think in terms of product substitution we have to think differently and not just about tweaking a molecule and hoping for the best. So how confident are we that the new non-fluorinated chemicals they go to are any better? And we got let out of gasoline and went to MTV and that certainly didn't help us a whole lot. So I mean, just because we get out of fluorinated is how do we know we're not getting into something that 10 years from now we're gonna find out it's even worse. Well, I know the work word funding we are looking at the toxicity also. You know, so at least with the work we're doing we're making that attempt to try to understand while still meeting the mill specs for being able to put out fires. It's challenging. I mean, at the presentation in November sort of BSTCP meeting from the person who was developing the alternative I think that was one of the points of discussion but it seems like they're getting pretty close to being able to meet the mill spec. It's not like it's very far away. You think they're way off? Well, that's the way he presented it in November. I was looking at Richard. Who is that? Do you remember? I can't remember his name. Yes, it's National Foam and the science. I mean, it's still sort of Richard. So, I mean. So I work with the Naval Sea Systems Command folks and any research lab folks that do all of the, they maintain, National Sea maintains the mill spec and NRL does all of the product valuations against the 28 or 30 performance based criteria within the mill spec. And we've had to respond as Maureen talked earlier to several requests from Congress about how close we are to having a Florian free foam that meets all our performance requirements and we are years away from that. I know they're looking at Silicon or Silicon-8 they're different replacements but the Florian free foams that have come in so far and tried to pass can't even pass the simplest of the 28 or 30 tests. They can't even do the 28 square foot fire at normal strength, the freshwater. So they can't even get to the tougher tests yet. So all of these foam companies that are out there that are making these claims that they have a Florian free foam that works. Well, it might work if you have less performance requirements than the mill spec does. Right now we don't have anything that's fair or that we think is on the cusp. At least when I talked to John Farley. No, no, I would say years is fair. You know, it's sort of research. So when I say we're getting close to a sort of that still means we've got ESCCP to get through to demonstrate it. In geologic time, we're really close. I probably can't hear me. EPA just released an RFA. It's a fast track RFA for $4 million. It's for two, $2 million awards. It closes on June 18th and the topic is PFAS. The agency is looking for three types of proposals. They can address any of the three or combine the three. One is on the fate and transport of the short, the long chain, both the precursors and the transformation products. The other is a comprehensive look at PFAS exposure. So it would be water food packaging. It would be from ingestion, inhalation, dermal. And then the third is information to inform hazard assessments. So MOA, PVPK, toxicity values and so forth. So it is on the website. It's not a star grant. It's authorized by a different congressional authority. It's called the national priorities, but you can find it on the EPA ENSER website. It's still listed there. Anything else before we go to break? The slight change of plans, not really, but we have about an hour of open sessions and we want to, and the board, we want to use this to the best advantage for the board. There are a number of people in the room from a variety of organizations, agencies and whatnot that obviously have interest in this issue. So without putting people too much on the spot that have come looking around at all of you, who are now I'm going to put someone on the spot, we'd really, the WSB, the board would really value better hearing from you what the interests you have in this issue are, what challenges, what research needs you're facing as another way to educate ourselves about the needs for research in this space. So think about that for just a second and I'm gonna, hopefully some one or two of you will volunteer to get us started and then we'll go around the room as much as possible. And then for any time that remains, I'd like to hear from the panel members or anybody, thoughts and ideas about how the national academies, the Water Science and Technology Board or a committee, whatever could be valuable in this space. You know, what could the academies do in its role as a convening authority, as a safe place to have conversations that are not political or at least not overtly political and so on. So that's gonna be the plan for the next 50 minutes or so. And I see a questioning face from David, yes. Well, I don't think you were referring the questions to me, but I'm not to put my other hand on of working with the Bureau of Reclamation and with the Corps and Joe isn't here now, but he and I did chat about this earlier today. About 10 years ago, we began to be impacted in the agencies with invasive mussels and snails coming in and affecting our hydropower plants in particular and our irrigation systems, water distribution systems and the Bureau in particular and I'm sorry Dave Raff isn't here today because he could speak to this with more knowledge, but the Bureau and the Corps began a project of looking at materials to coat pipes and intake valves, everything where the mussels were attaching themselves on Hoover Dam or Glen Canyon Dam, et cetera. And we were chatting earlier today about what's happening up in Michigan. And I know some of the power plants up on Lake Michigan that draw cooling water in, they were having impacts associated and once you get these mussels growing, they reduce the diameter of the pipes so it reduces your water flow. And the question I asked Joe and he was gonna go back and ask his people is the Bureau was looking at all kinds of different Teflon related compounds to coat the pipes because they were seeing that they were thinking that those would reduce the opportunity for the little villagers, the little snails to attach. And I'm just, from a pure operational point of view, that to me from the agencies is an area that we need to at least explore and seeing whether it has an impact today because certainly it's a huge operation and management issue, maintenance issue for the agencies. That's all I meant to say. Do I have a volunteer from around the room? I see one moving and we'll go with you second. Thank you very much. Yeah, yeah, yeah. Thank you. And people can join us at the table. Yeah, and yeah, Mike and you, however, please join. Come on up, because we're gonna see that. Yeah. Yeah. We've been very involved in this and actually in a past life with the EPA's Office of Criminal Enforcement I was involved in this issue in the early 2000s. And so it's both interesting to me, a little frustrating. But there are many things that NIEHS and I joined the NIEHS about eight years ago now at the request of the director. One of, there are so many things I'm not sure exactly where to start. David and I were talking about something that came up today that we've been thinking about for a long time and actually working with the Consumer Product Safety Commission on. And that is the concept regulating chemicals by class or addressing them. I'm no longer a regulator addressing them by class. And David in his presentation gave us really some practical tools for beginning to step into that arena. Coupling the kind of chemistry tools that David put forward with high throughput screening, the identification of adverse outcome pathways or using other alternative toxicological tools might let us address this class of chemicals based upon what I think EPA would call effects-based monitoring where we would even have the ability to look at mixtures, chemicals, point of exposure, adverse outcomes and regulate that class this way or that way. Another thing that we're very interested in, and by the way, Jenny, you were interested in what kind of research is going on. We have over 193 studies underway right now ranging from human epidemiological studies to biochemical studies to superfund research, et cetera, in many of the chemicals that you address. So you may, if you wanna see what's going on, you can, and Helen already knows this, Helen Gaten, I'm sure you can go to our website and look those up. One of the things that we're very interested in now is coupling what we understand, the mechanisms of toxicity are in animal studies and biochemical studies with what we see among the tens of thousands, hundreds of thousands of people that we have under epidemiological studies. The question being, and Peter addressed this right out front, what does this mean? Are we overreacting? Are we actually seeing effects in the epidemiological studies that we have going on? We obviously can't dose humans, but we can do dose reconstruction studies and try and correlate effects that we're seeing, particularly in children in those epidemiological studies with what we see in the laboratories and in the mechanistic studies that we have going on. We have a number of activities going on working with the Office of Science and Technology Policy on a summer long approach to emerging chemicals. We're very interested in working on that. And I guess to wrap it up, we are NIH, you may know, has an increase in their budget. It looks like we'll get a small increase in our budget. And of course, we invite grant proposals from folks who have practical and applied basic research interests and needs and this area is a hot area, so I encourage you to do that. Thank you, that was excellent. Hi, Stephanie Schley. I'm the Regulatory and Scientific Affairs Manager for the Association of Metropolitan Water Agencies. I know, it's really long. So caveat, I have been in this position only nine months. And beforehand, I was state regulator, so I have kind of a couple of different views going into it, but I think a big one. So AMWAL represents the public drinking water utilities of 100,000 or more. So very large drinking water utilities. And I think a lot of it for our members is regardless of which way we go with this, if it ends up being a health advisory like it is with PFO or PFOS, if we do end up with an MCL or something else. Obviously, we would love for it to be dealt with as the source before it ever got to the utilities, but with so many unknowns with chemicals like these and with so many chemicals in this family, it really is gonna come back a lot to risk communication. Trying to explain to people that you have a health advisory level, but you don't really know what the impacts of that level are. You don't really understand why it's quite at that level. And it's not just even if we do have the information explaining that to an average person it can be very difficult. And so that's a large component of our utilities is even the ones who currently have PFOS or PFOA, they're still struggling with that risk communication to the public and trying to, especially in the time that we're living in now where the public is extremely critical and extremely aware more than maybe they've ever been before, which is a good thing. But it's really bridging that gap and trying to figure out how you keep the public well informed without scaring anyone without putting the blame on the utilities since they are the ones who are gonna have to deal with it in some form. And so that's really kind of, I hammer that all the time and Wendy will probably hammer it with me again. Risk communication is probably the biggest issue for us and why I'm mostly here. Oh, Wendy's gonna go, Wendy's gonna do it. I saw the eyes looking at me, I saw them since my turn. Yeah, I mean, certainly, so I'm with the American Water Works Association. And I think, and Stephanie and I have been talking about this kind of off and on all day. I mean, just thinking about all of the different groups that are here represented. I mean, this is a huge issue that goes far beyond just my normal corner of water. And I think this is a real opportunity to kind of change the way we have been addressing contaminants of concern. And AWWA has been vocal about our frustration with the health advisories. And so that might not come to a surprise to anybody when I say that we didn't love that process. It posed a huge challenge for risk communication. And I would say we do have some members who were thrilled to have a number to point to and something that they could use. Some of our members were glad to have a health advisory, at least have some number. But so I think this, the way that maybe EPA has addressed, it's just been a frustrating process. So I'm glad to have everybody here together. And this as well as EPA's upcoming summit, AWW is very much looking forward to participating in. But you know, think about it. We've talked about the Clean Water Act, the Safe Drinking Water Act. We've talked about TOSCA. Somebody mentioned the Endangered Species Act. I mean, that's pretty, that's how many different offices within EPA. And you know, I've, I, not, is anyone from EPA here? Okay, okay, yeah, yeah. So I'm really thinking that this, okay, yeah. Well, no, I mean, I'm thinking this is a real opportunity for EPA to say, we've got all of these different pieces. How do we fit them all together to properly address this contaminant? And, you know, I'm a young professional, is I think like the proper term for it. So I haven't been around and I don't have the history that, you know, a lot of my colleagues do. So maybe this has happened in the past where we've really come together and brought, you know, the Toxic Substance Control Act and said, here is your role in this. And here is the Office of Water's role in this. And if I have that, I'd love to hear about it. But, you know, I think this is a really cool opportunity. Stephanie and I are really excited to kind of be in on the ground level of this, because we hear about from our colleagues for Chlorate and Leading Copper, you know, get the histories on this. So anyway, but in terms of risk communication is huge. Having a real understanding of the health effects and what we're trying to achieve and how we measure a reduction in risk, huge. I mean, we definitely need that. If we're talking about spending $2 billion with somebody's estimate, yeah. And we need to be able to quantify that and say, this is what we're trying to do by spending that money. You start to think about the treatment techniques. And, you know, I was also a state regulator before this position. And so I think about those tiny systems that I worked with who were struggling to reach out to the community struggling to run a one-well system. I mean, struggling to chlorinate. And I think about them trying to run innovative technology. I mean, come on. It's just, you're trying to be realistic about the approach. So that was really scattered and not very eloquent, but that's kind of my thoughts on the subject right now. So that was very helpful. Thank you. A follow-up question. I'm not familiar with how EPA rolled those numbers up. It was very clear that there was some problems. Could you just give a really brief, what was bad about what they did and just a real quick for those of us who don't know the story? Well, neither one of us were around when that happened. But sorry, it was pretty recent. I mean, yes, these jobs. Oh gosh, yeah, we existed. I think from what I've heard was from some of our members, was there was a lot of kind of numbers being thrown around and there was some communication before they rolled out the health advisory, but it was all higher. And so they were prepping for a higher number and they weren't too concerned. And then when the lower number rolled out, they weren't prepared. And so they knew a health advisory was coming, I believe, but the problem was the number wasn't certain. And so they had been hearing a higher number and when it rolled out, a lot of them had to close wells that they weren't prepared to close. Well, not a lot of them. I know of a couple who had to close wells that weren't prepared. And again, it came back to the risk communication was the public heard health advisory heard that above 70 is bad. My well, my drinking water has above that, but there's nothing mandating the utility do anything about it at that moment. As far as like a regulatory standpoint, there's nothing saying that they have to, it's not a standard. And so they didn't, I don't think they didn't have the prep time to deal with that. Yeah, and I would just say that because of that, it came with all of the burden of a national primary drinking water standard without any of the analysis that comes along with producing a national, maybe not any of the analysis, but some of the analysis that comes along with a national primary drinking water standard. So it really hamstrung a lot of utilities in terms of how to respond. And it was all of a sudden a really big issue for some communities who really weren't prepared for it to be. And I think it caught a lot of people by surprise and that's where a lot of the frustration came from. If others have things to add. Yeah, if there's a correction or something. So to provide a little context here, everything they said was right. Oh yeah. So, but a little more of the background. So there was a preliminary health advisory that was out there and there was more risk assessment work. And it went out for a peer review and there were a whole bunch of public comments that were submitted. And then EPA went radio silence. And then there was a whole bunch of internal kerfuffle about we need to do something, we need to do something, we need to do something. And they called us and they said, we're gonna do something. We're like, okay, what is it? Are you gonna go through the process? You know, another peer review or show us how you responded to comments and all of that. And they said, no, we need to do something now. This was in the spring of 2016. And then. Right, right. Yeah, they called us like four weeks before and they said, we're gonna do something but we can't share with anything with you at all. And then they called us, like Richard said, two days before and they said, the number is gonna, we can't tell you, we can't share any of the documents but this is what we're gonna roll out and we're gonna roll it out as a big to do. No justification at all. And of course, it came on the heels of Flint. So people are already are all up in arms about how safe is my drinking water? And EPA made a big deal of rolling it out. And again, like was said, it's an advisory. There's no regulatory authority behind it. They also did not take into consideration that it actually drives a cleanup requirement under CERCLA for all the rest of us. And they also said, well, it comes from firefighting foam. So, you know, and it's like, so there was also, so the whole rollout, in my mind, just fan the flames because there was no risk communication associated with it. People were under the impression that this was worse than anything else. Now, they had already taken action against us. They had already issued against the Air Force a imminent and substantial endangerment in the Navy. That's right, two places. Prior to that saying that we believe that this is so bad, there's an imminent substantial endangerment at two locations. It's P's Air Force Base and War Minister. P's Air Force Base in New Hampshire, War Minister in Pennsylvania, and said, these are so bad, you have to act now. So they're sending all these signals. These are unregulated contaminants, but their authority under Safe Drinking Water Act is so broad that they have the ability to do that. So that's why I made the point of risk communication. I think they're absolutely right on there. What is the risk? How do we describe to the community what these risks are and what does it mean for them if they're drinking the water now versus having drank the water for the past 20 years versus the volumes of all of that? So, I think in terms of the risk communication, it actually does have some similarities to lead in terms of listening to what the toxicologists have been telling us. It's quite possible that from a toxicological standpoint, the one in a million lifetime cancer risk or whatever the adverse outcome pathway is might lead to a very low standard. But as we heard this morning from Peter Gravatt, the determination of an MCL depends upon meaningful opportunities to reduce risk and cost. And so, you know, our SNCC was geogenic and you could say, well, that's just what people always had. But the only one I can think of where you have something that is a result of human activity, which is lead pipes and legacy lead pipe use, but was too expensive to solve the problem immediately. So it went into a management perspective is led. And I'm kind of curious from the risk communication standpoint, whether there are any other examples that people know of when there's a, an anthropogenic contaminant that is in water supplies, but is too expensive to clean up. And so we end up as a society choosing a higher risk level, but rely upon the cost and feasibility of treatment. Cause, you know, the logical endpoint is, you know, activated carbon like crazy in all the drinking water treatment plants. And that would be the economic analysis I think someone would start doing, okay, you can't do it in small systems to say can't afford it, but, you know, here and here and here, you would, are there other examples that you can think of from drinking water? I think this is gonna get huge though, because right now, I mean, going back to the UCMR, there were only six performance that were looked for. We're only two that have lifetime health advisories and there were only 63 public water systems across the nation that had these DODs taken action where we're the responsible party for the one of those 63 plus any of the other ones where we have them on our installations or near our installations. I think as we move forward and as more smaller public water systems start to test for these, and as they start to look for other performance that have no tax values with them, that if there's a decision to start addressing all these unknowns down to significant low numbers, there's not gonna be an easily locatable responsible party to pin the bill on, in which case, if the communities cry out for, I want none of this in my water, it's gonna turn right around and the bill is gonna go to them in their water rates. And that's the only way that there's gonna be a put and take on what is an acceptable level of risk and risk reduction and what's the cost of that risk reduction. Okay, I have to jump in here. So I'm an economist. I said that for you. I actually know about the basic cost. Okay, I'm doing a little back to the envelope here. Six million, you'd said, so six million people are being exposed in their 1.5% in drinking water, right? That was the number you gave it. Okay, so Ken, there's nothing else out there, just that six million. Suppose, and this is, I'm totally making this up, there's one in a thousand risk of cancer from that. Way too high, how much too high? One in 10,000? No, no, just bear with me, come on. One in 10,000? Just give me a, it's a made up number. I get it. I'm just gonna hold you. I just bought it. You wanted a million. EPA kicked out the assessment thousand. No, one in 100,000. There you go, middle ground. Okay, five zeros. Okay, I got rid of three at two more zeros. Okay, so the way we do benefit cost analysis, the cost of remediation is important, that's part of it, but that's not the benefits. Okay, the benefits are the improvement in human health and life and the value we place in living longer, living healthier. We have those concepts called the value of statistical life. All it means is the value of, that we are willing as individuals in society to spend a lot of money to prevent premature deaths and mortality. Okay, a number that is often used as $8 million per statistical life. So if I multiply eight times six, then I just have to get the right number of zeros behind it. And that's, so when I was using one in 100, I had 48 trillion dollars in benefits. If it's one in 10,000, now we're at 480 million. I don't know, I can't do it. The point, and it depends on that probability that none of us actually know, and that also presents on there only being $6 million. And what you're telling me is that this stuff is far more expensive than that. So if you're thinking about making arguments on the economics, a little back of the envelope tells me we are definitely in the territory here where this is the kind of risk our society has in many ways, lead and other places, drinking water, unless I'm way off with my zeros. So I just wanted to throw that into the communication. So I wanna make two points. One is, and I think somebody said it earlier, there's about 200 lifetime health advisories that EPA has issued. Only about 100 have resulted in MCLs. Of the 100, the lifetime health advisories that are still there that haven't had an MCL, why are these two more important than any of the other ones? Which I don't understand, you know, in my mind. So I think that's a broader question. What is it about these two that cause society as a whole in the United States to act so strongly? And I don't, yeah, yeah. My EPA did it the way they did it. Right, right. But the second question is, and Jenny did a great job in terms of tracing the numbers, but the question is, in my mind, do we fully understand the risks? And I'm not quite sure that we understand the risk to be able to do those calculations. So what is, so we as a society, these chemicals are out there, they're in everybody's blood, has our health across the nation deteriorated that much as a result of having this exposure. That's where I don't know, and I would advocate that there probably needs to be a lot more research. Are we chasing it because we have the ability to detect that low? Or are we chasing it because there are, in fact, known health risks to factor into that decision-making? I honestly don't know the answer to that question. I mean, that's a funny question. One, the quote that number would be eight times the risk. But I am afraid that because of the way that we have approached this across the United States as a whole, that it is, we've created a fear without having the information, and that's why you hear this risk communication message among so many different people is, well, what exactly is the risk? So people can understand and make an informed decision. I don't have an answer to that question. I just wanted to say that. But in response to the question you asked, David, I think disinfection byproducts are, you know, the health risks are clear. They're well understood. We're all exposed. We trade that off, of course, with, you know, diminishing risk from bacterial or viral contamination. You know, if we listened to Peter this morning, perhaps we're trading the exposure to these fluorinated chemicals with our love of Gore-Tex. But, you know, it is, there is a societal thing. You know, I think that's where the academy can really open those discussions up. And so the answer to the question that Maureen just asked, what is the importance of this? We have, for example, bring the epidemiologists together with the toxicologists and say, compare notes. And, you know, maybe there is evidence that pursuing this is worth the cost and maybe not. Okay, I'm not going to, I'm sorry, we hijacked this. But one quick thing just to keep, because I like that we have an economist over here No, because no, I mean, I do. But I like all the economists. You're all great. But I think the other big, one of the top issues that we're having right now for drinking water utilities is affordability. And that seems to only be getting worse. And so that's one of the things, I love the view of the society, like we should, you know, invest where it matters and what we think is society. And I wholeheartedly get behind that. But for us as a day-to-day, whatever we have to invest in utility goes on to the rate payer typically. So if we're already having trouble with our public being able to afford their water bills and it's only getting worse, then where's again that trade off? So they can't even afford it. And Wendy's looking at me like she wants it. Yeah, I was just going to say, this is something we talk about with lead, right? Because we have this huge cost for moving lead service lines. And so comparing lead risks, I mean, if we don't do this, but if we did, would you rather invest in removing lead service lines or would you rather invest in moving people at PFAS from your system? I mean... But you know, I mean, that's part of it. And on the affordability, I work quite a bit in affordability and it is very interesting because water and wastewater service is nine times out of 10, you're lowest bill. But we hear a lot about water affordability because of this necessity to have water. And so I don't want to make this an affordability conversation, but it is interesting to keep that in perspective. There is a societal pressure on water that we don't have necessarily on other utilities. And so it is a very interesting and can be a very sticky subject and it is very close to people. It's their day to day, right? Water, you have to have it. So just to keep in the back of your mind. Are there health risks associated with setting aside, you know, fire retardants? Are there health risks associated with not using it in some products? I think that's also a bit of a false dichotomy to claim that it's one or the other. And I would like to see the numbers on, of course, you know, the added drinking water treatment plan, especially when we talk about large systems, you know, we're often talking about something like PAC or GAC and there are other benefits that people would have from surface water treatment, putting an activated carbon is kind of a standard because there are other contaminants that would be removed and the aesthetics of the water would be improved. But I just question that and think that there's another thing going on with the water industry and that's a consumer confidence issue when less than, what is it, a third of Americans drink water from the tap without treating it or they drink bottles of water. I think that's something the water industry should be thinking about is that these stories are going to keep coming out in the media, no matter what you do and it feeds into the diminished public confidence in the water supply which will make it harder for water utilities to ask for rate increases. So I think the water industry could consider being taking the higher path and saying that if other societal activities are polluting the water supply, it may not be on the consumer to pay for that but it may be on the people who manufactured and use those chemicals. And in this case, we're not talking about most of the contamination sources we talked about today were from the users, not from the diffuse sources. So it's not like the pharmaceuticals or the consumer products or lawn care or nitrogen non-point sources. It's a manageable number of distinct sources like what Jenny talked about in Minnesota was what $860 million settlement and I presume some of that money will go to drinking water utilities. So that's another way for the water industry to think about this is that to be advocates for your consumers maybe you could think about the kinds of ways in which Minnesota was able to recover some of the costs to protect public health. Well, I have to speak up for my state of Iowa where the Des Moines water works for nitrate pollution in water. So as we're talking about this, I'm also thinking about risks from nitrates in groundwater wells that people are drinking above the 10 parts per million drinking water standard. So that's another form of all this. But yeah, there's a whole host of things in our drinking water, all of which have risks and it would be nice to know what all of those risks are. I was just going to say that was the I mean, that's why we don't do a comparative risk that way it's because you're absolutely right. But well, you know, I mean, the benefits from adding GAC or something are going to go beyond PFOA PFAS. So the point is well taken and I would love to have some settlements to pay for drinking water upgrades. I mean, whether or not maybe it is realistic and maybe it's something that we can get to. From the Air Force standpoint and just to bring it back to the old way of doing business which is respond and go and leave is not in place anymore. We've replaced foot Air Force across our installations across. We've replaced the old solvent 3M 6886 54321. Just kidding. Y'all see who's listening. The C8 with the C6 which is approved for mill specs. The bottom line is we use it to save lives. Right. Okay, everyone understands that. What we've done is changed our processes. We used to go out in the mornings and we spray and see if the vehicles worked and we leave and drive away and that's been happening forever. That has changed. We've changed the process. There's no longer free spray and where we do respond to an incident that area is identified as a spill area and we clean it. So we don't respond to an incident and leave it. Just referencing for in here the C130 incident that happened down in Savannah the latest flight accident. We're treating that as a spill and we will clean up that area associated with our EFFF usage. So that's what the Air National Guard and Air Force is doing there. So what has happened over 30 plus years maybe longer of expenditures of EFFF on vehicle testing is happening all across our installations two to three times a day just practice training lots of usage. That philosophy has changed. So the contributing factor for at least for EFFF associated contamination the contributing factor of testing and equipment validations has been revised and upgraded. So that factor shouldn't be I guess what I'm saying is we're not pouring the water and leaving it anymore. So that's a significant impact for the future. Thanks. I just am looking at the EPA Health Advisory Online and May 2016 is the data associated with all the documents. I have not read the 388 pages yet for PFOS but maybe somebody has Chapter 4 is the dose response if we have a dose response relationship for at least one compound presumably it could be developed for others. I don't quite see where the disconnect is between we can't figure out what the risk is. I mean it seems like some of the toxicology the basic chemistry has been done. So I'm a little confused about why we keep saying we can't figure out the risk. Now maybe the studies that they base the Health Advisory on are a bunch of crap. I don't know if that's true. Somebody let me know. It's there at the moment. Well that was my point that those documents did not go through a peer review process. So you think it's crap. I don't know. It could be perfectly great but I don't know. So that's my point. Later nobody has said it's crap or nobody is going to look at it. I'd recommend, I think you may have insight Chris, but I think what happened in New Jersey with the derivation of the standards and that you know that looking at the same basic data New Jersey came out with a number that was quite different than the federal EPA at the time and my understanding of risk assessment and kind of how those numbers come it's like different scientists choose different safety factors and squint different ways and we're talking about logarithms of differences and so when you're within the factor of ten of each other it's like you got the same answer it's just that people came up with different assumptions along the line and so this is exactly the point Marine about peer review of things and peer review that's done in a rigorous, transparent manner to create confidence that people can invest money in cleaning up or people can walk away with confidence that they're not endangering public health and I just feel like rushing to get something out on the street without that peer review process on such a large expensive problem seems short-sighted. So Laura I agree with the peer review stuff but Laura let me try and answer your question a little more directly so on the one hand you do have the those RFDs that are in the health advisory that allow them to come up with less and health advisory the way the Safe Drinking Water Act is established if you can't determine what your relative source is from drinking water or from anything else the default value is 20% so when they ran the risk assessment for each of PFOA and PFOA the numbers were in as Marine was saying before in the 380 to 400 range and when you actually apply the relative source contribution you come down to 73 but then they have to round it to 1 sniff and figure so it becomes 70 so that's how they got the 70 and then they somehow said well we're going to get additive and so that wasn't in any of the other risk assessments so now you're additive at 70 but now when we go under CERCLA even if we take those RFDs which EPA has yet to put them in their RSL calculator so that everyone use them for screening and for actual risk assessments even if we go and do that we're going to come up with numbers of 400 for each chemical and so under CERCLA not additive so now you're going to have a CERCLA risk assessment that says hey if I have less than 400 each I do not have unacceptable risk in which case I don't take an action I also don't look at state appropriate requirements so I don't look at state numbers so if I have 50 I say I'm done but what if I've already been proactive and I've already provided alternative water to a private well or a public well at 70 now I go wait a minute I did a removal action under CERCLA that allowed me to give you water because I proactively used lifetime health advisory but now I've actually run a CERCLA risk assessment and I don't have unacceptable risk yeah I mean so we're in a huge quandary and just two of the regulations out there we haven't talked about clean water act what can go out in an MPBS permit or not an MPBS permit where's Tosca going to go so there's a ton of uncertainty just with those two chemicals and so I think we would like some sort of definitive drinking water and or clean up standards so that we know exactly what to do and having them peer reviewed so that everyone is comfortable with the science behind that would be very valuable and from a risk communication standpoint I mean we started off where we were very careful when we went and sampled people's wells you know I come into your yard I say I potentially impact your well I'd like to sample it well first we look at only PFOA be false so we know we're running a 537 analysis we know we can get 14 analytes but what do we tell them if we have detections of the other 12 and there's no numbers so we start looking at only two and then we got criticized for well why are you not getting the other data when you can get it for the same cost for the analysis okay we'll get all 14 now we have other numbers and we start to hear your results for PFOA be false and here's all your other stuff but we can only make decisions on these two well why aren't you doing something about those I mean that and that's only now 14 of 3,000 the other thing on the risk communication part of the sorry to jump in here is we're getting pressure to go below 70 the communities want zero non-detect and they are they go to their members of Congress and say DOD is not being responsive because they're only going to 70 they're not going below 70 and I want I want I want them to go down to zero non-detect but based on what because we've scared the bejesus out of them that this is harmful so but what's so magic about 70 and how do we explain that doesn't that pretty simple sort of what I'm hearing in my very simple 10,000 foot level here is there is science on the toxicology but there's plenty of uncertainty about that and that science only translates into valuable information when someone decides what the trade-offs are that make it acceptable versus not whether you use a cost-benefit analysis score x percent risk rate or whatever you use you have to not just have the data that you believe and trust but you also then have to transfer that and then I'm hearing that and the all that there's a whole series of different laws and rules that have different trade-off mechanisms and decisions about where which complicates that and then on top of it I'm hearing that EPA has done a very poor job in communicating and explaining its process and transparency so that the folks on the ground actually doing this stuff like you are actually between the cross hairs I mix a lot of metaphors you're between some kind of bows or hairs or something I don't know and so there is a science piece in fact there's multiple science pieces but then there's also institutional and other things that are jamming up the works that I just want to remind people that you can make an eloquent argument for 400 but there are professionals in other states like in New Jersey who have looked at the science and gone through a regulatory process and came out with numbers that are lower and just last week we heard that maybe the direction that some of the science takes us so that's why I think having that discussion about what do you do if actually the peer reviewed science and the deliberative discussions come up with a number that is going to mean just too high a cost to do this as a society then what's that path look like so I think that what I can tell from the science right now is we need to get all the opinions together in a room have a transparent process that is done by the public and let it play out where it will recognizing that one outcome is that there's a very small number of places where we really have to worry and another possible outcome is that based purely on health alone it won't set what we do it will have to be some sort of management as we've done in disinfection byproducts and lead and other contaminants in the past and that's something we can't know until it's been done because I think there's too much uncertainty now about this. Really what we're doing is merging knowledge not necessarily emerging contaminants but the toxicology is going to continue to get more and more precise it's going to lead to changing values with respect to what's acceptable for human exposure Jenny enlightened us to that with this every day every time you make a measurement your knowledge new knowledge emerges about the fate and transport and really what's needed is a process a risk communication process that can handle that kind of constantly emerging knowledge and you know we throughout my career the first 22 as a regulator and now as a science advisor I've always dealt with that you always as we learn more about lead the value keeps going lower and lower and lower we don't do a good job at educating the public about or communicating is probably a better we're communicating to the public about emerging knowledge other thoughts Wendy I know nothing about this I'm just wondering who's missing here that could explain to us EPA's rationale for how they rolled out this health advisory limit I mean I would be fascinated to hear that but on the other hand perhaps that's water under the bridge from moving forward I don't know whether that would change if we had more information how we would move forward just a question I was going to comment calling risk communication these issues don't sound like risk communication to me these sound like we learn new stuff and when we learn new stuff we understand the risks better and I mean one problem economists always have is the idea that there's a one number that there's somehow these mass of these thresholds that somehow mean something so at 71 you're fine at 69 all hell it's a crisis the science doesn't support that in many cases I know there are some things that have these and so as we're better able to be more precise and we know there's risk lower usually the risks are higher as you get to higher numbers and lower you know there's a trade-off between how much you're willing to spend and you know now you're hearing the mantra of the economist and make the trade-offs weigh things back and forth but you have to have the best science you can about what that distribution of trade-offs looks like and then you have to have the best notion of what the remediation options are what science can be done to advance those and think about that set of trade-offs so rather than communicating to the public this is the number oh now this is the number in a more sensible way in my mind is well we used to say we think at this number there's very slow at 70 there's about no risk of that one in 10 billion cancers we've now done more analysis and now we know at 70 it's actually more like one in 100 million and we're learning more and so it might be worth investing a little more than we used to think it was to do these sorts of things but the sort of you just want to give people one number I know that's what's easy and that's what you guys have to deal with in reality but it's a much more nuanced it's done you know behind the scenes one would hope that there's a more trade-off anyway that's I'm getting off into a separate thing how about and do we have to stop because it's open session at one week okay so that's I think and Wendy correct me if you think I think what the utilities are saying it's exactly what you just said where I think the problem we're having like with lead right now is there's CDC says there's no safe level of lead so if anybody if there's any lead at all they're just this is bad my drinking water is not safe and I don't want to go into discussion on lead just using that and so that's where the issue is like what you're saying is a trade-off our members are trying to tell people our people are struggling with we have PFAS period in our drinking water system and that's all the customers seeing they don't understand that this much like you said that this level means this risk that's literally what we're saying when we talk about risk communication Wendy do you think differently okay yeah so that's you know if we get a number the number is really just for when Wendy was saying some of our people were happy to get the number it's because that's something easy to get out to public versus having to break down other parts but that's kind of what we're talking about even when folks get scared about the water they're still uninformed because instead of paying pennies per thousands of gallons for the water that is all tested and meets the safe drink water act requirements they go and buy bottle water for $1.50 a bottle that FDA does not follow all the same safe drink water standards so they have no idea what trade-off they've just made and the expense that they put into that yeah so there's multiple levels I was just I was just agreeing that we're getting we're looking beyond just one number to tell people or they do what I do which is buy diet coke and just put on all kinds of chemicals you don't know what they are and say this must be safe but coke has a city level of about 2.5 and so you might be able to treat the PFAS with that with a little bit of I knew that stuff was good for you don't tell Coca-Cola that did you just make the point that one of their water bottles and just find in the middle of that glue green water from you on the other hand would you test their water and they use carbon filtration as the bottom of the water so the ones we tested are fine but yeah it is kind of incomprehensible thinking would add you know some of this also just goes to the credibility that you can build with the public and you know one of the when we first started doing public meetings back in 2004 when we had almost nothing to tell people the only thing we could do was promise them we would follow the science and we promised them the numbers were going to change over time we said we can guarantee that will be the case here's the numbers we are using now we will be back in a few years with those numbers and we want to warn you of that because that's just how these things go and frankly I think that bought us a lot of credibility with the public that at least we were up front and said we don't know and I think you know it's hard to stand in front of a group of people who are scared and upset and tell them you don't know and so it's hard for all of us to do that some reassurance we want to comfort them I frankly feel bad about some of the comfort I've tried to give to people because then later they call me back and they said you told me you saw that this was okay and now you're telling me it's not but I think you know in all of this we have to be really cognizant of some of the things you've been talking about is that we just have to be a lot more up front with people and help them understand that science doesn't have the answers it's got the questions and that's what we don't teach people in our schools and that because it's always questioning it always evolves and so one of the things we're going to try to do with our document with ITRC we've added a section on risk communication and we're going to try to provide resources for folks about that both trying to gather all the links and sources we can for materials that are already developed and then it would be really helpful to have input from people about what they need from different perspectives like the water you know water system operators and what they're trying to address and you know from the different perspectives of how you're trying to interact with the public so I'll just put it out there that you know the more people who can help us review and comment and help us the more useful they'll be to people okay anybody I think we've had an extremely good conversation the last hour so we'll bring the open session to a close take a break and board members please return in 15 ish minutes no sneak into the bar just yet thank you