Ms. Kellogg has 25 years of experience investigating and remediating contaminated sites in New York and New Jersey. For the past 15 years, she has lead multi-disciplinary teams to create innovative and cost-effective solutions to complex environmental challenges. Ms. Kellogg assists industrial, aviation and water supply clients in managing, characterizing and remediating their PFAS liabilities. She has become an industry leader in evaluating and managing PFAS including co-authoring the first PFAS best practices guidance (NGWA 2018), educating industry professionals on the unique challenges of characterizing and remediating PFAS and providing technical advice to congressional and state staff on PFAS policy. Additional areas of technical expertise include chlorinated solvents and DNAPL in groundwater, aqueous geochemistry (wet chemistry and stable isotopes), contaminated sediments (characterization, management and natural attenuation) and mercury.
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.