Dr. Benaman is a Principal at Anchor QEA specializing in contaminated sediments, fate and transport of chemicals in the environment, and water quality of natural systems. She has worked on some of the largest Superfund sites in the country, including the Hudson River, New York and Lavaca Bay, Texas. Her expertise includes the development and application of watershed and water quality models for simulation of eutrophication and toxic fate and transport. More recently, Dr. Benaman has worked in the area of PFAS fate and transport, including understanding the chemicals' bioaccumulation in the aquatic food chain and effective remedial alternatives.
PFAS and CERCLA: The Next Frontier?
Per- and polyfluoroalkyl substances (PFAS) have been gaining wide regulatory attention on the federal and state level. Lawsuits filed in numerous states, public pressure, and uncertainties regarding the potential risk of this class of chemicals have led the EPA to consider adding two PFAS, PFOS and PFOA, to the federal list of hazardous substances. This action may have broad implications for existing contaminated sites and may create a whole new list of sites that fall under the regulatory authority of CERCLA and/or RCRA. This talk will briefly overview PFOS and PFOA and explore the impacts of a hazardous substance listing for these chemicals, including factors to consider if a site is listed on the NPL solely for PFAS. For example, the fate characteristics of these chemicals will impact site characterization approaches and technologies that are viable remedial options for these chemicals. There can be fundamental differences from the approaches used for typical legacy pollutants, like PCBs. Particular attention will be given to existing sites and how the possible detection of PFOS or PFOA at an existing site may impact the ongoing regulatory process. The impact of such a detection will depend on the levels detected, the media of concern, the other site risks, and where the site is in the CERCLA/RCRA process. Important questions to consider and factors to incorporate into the process will be discussed for groundwater and surface water sites, including the implications of the recently released groundwater PFAS screening level guidance values, how and/or when to possibly assess risk of PFAS relative to other chemicals on the site, and what to consider if fish tissue concentrations are a potential concern. Finally, we will discuss how and whether one can assess the impact of proposed alternatives on PFAS concentrations and whether adaptions of those alternatives might provide a dual benefit of treating the original contaminant of potential concern (COPC) along with the PFAS, if it determined that the PFAS is a COPC.