Dr. Dorrance is an environmental scientist specializing in contaminant chemistry, environmental forensics, and litigation support. In addition to her academic background in geochemistry, she has over nine years of consulting experience implementing site investigations, managing environmental data, coordinating projects, and providing technical support to counsel. Dr. Dorrance applies her expertise in geochemical analyses and environmental forensic techniques to addressing contamination at large CERCLA sites and smaller properties impacted by contaminants including VOCs, metals, PCBs, and PFAS. She has supported multiple clients with environmental liabilities stemming from large-scale contaminated sediment sites (so-called sediment “mega-sites”), where forensics can play a key role in allocation of cleanup costs among responsible parties. Dr. Dorrance also has experience investigating ways to forensically identify sources of PFAS contamination to the environment. Dr. Dorrance has presented at conferences nationwide on topics related to her practice, including recent litigation surrounding PFAS and potential forensic tools for managing PFAS liabilities.
Managing AFFF: How to Reduce Your Environmental Liabilities while Maintaining Regulatory Compliance
Over the past few years we have witnessed the transition of PFAS from a group of emerging contaminants to the epicenter of environmental news, with a focus on aqueous film forming foam (AFFF). This transition has occurred in parallel with a rush of PFAS-related regulatory actions at the local, state and Federal level. However, many national, state and local fire codes still require the use of Class 3B AFFF with little guidance on transitioning from legacy C8 AFFF to newer formulations. Changing the type or chemical formulation of AFFF at your site can require significant hazardous materials management and compliance challenges. Given this highly charged landscape, managing the use and storage of AFFF requires understanding the compliance requirements, AFFF alternatives and environmental risk factors. Managing AFFF liabilities also requires an understanding of other potential PFAS sources in the vicinity. The application of environmental forensic techniques, where possible, as a means of differentiating sources, establishing divisibility, and potentially identifying additional responsible parties is one means of limiting liability. Similar to “traditional” chemical classes (e.g. PAHs, PCBs), PFAS can be subject to techniques including structural analyses, chemical fingerprinting, ratio comparisons, and use of statistical tools. As with other forensic tools, potentially confounding factors and site-specific limitations must be considered. Successful management of PFAS liabilities can be achieved through a combination of proactive AFFF risk reduction strategies and the use of environmental forensic evaluation to identify and differentiate among multiple sources.