PFAS and Site Investigations
Site Assessment and Due Diligence for PFAS
PFAS and Site Investigations
PFAS or “Forever Chemicals” are of increasing concern for the public, regulators, and developers especially of brownfield sites. But PFAS contamination can be found in a wide range of locations and understanding the full context of your development site is important. PFAS contamination is now impacting and causing delays for brownfield regeneration projects in the UK. But a robust, risk-based management of PFAS can help progress with developing brownfield sites and mitigate PFAS impact.
It is important to incorporate PFAS consideration early in the development of a site, especially if the land has a historic PFAS high risk.
Do I need a PFAS Risk Assessment?
If you are developing a site which is, or was historically linked to PFAS, then it is prudent to complete a PFAS Risk Assessment as part of site assessment and due diligence.
These locations include:
- Landfill Sites
- Fire Stations
- Water Treatment Facilities
- Aviation and aerospace (military and civil airfields)
- Paper and Cardboard Manufacturing
- Textile Manufacturers including Carpet Manufacturing
- Mineral & Cement Industry
- Food and Drink Manufacturers
- Sewage exposed land
- Chemical works (cosmetic/personal care products)
- Chrome Plating sites
- Electronics manufacturing
- Firefighting – class B firefighting foams (fire training area/fire stations)
- Military bases
- Petrochemical industry
- PFAS production
- Photolithography and semiconductor lithography
- Leather Manufacturing
Should PFAS testing be included in your site investigations?
PFAS Risk Assessment – The First Step
A comprehensive initial assessment commonly starts with developing an understanding of:
- Potential PFAS uses in the area
- History of the site operations
- Regional geologic and hydrologic framework
- Potential Pathways of PFAS on the site
If a desk study identifies PFAS risk then specific soil testing should be included in the scope of work. Sampling can be screened depending on the historic use or potential contaminants identified.
PFAS Site Assessment- The Second Step
Site Investigations should be completed if there is the potential of PFAS contamination. Development projects are facing serious delays as developers are told to re-run site investigations, and uncertainty over future PFAS regulation is causing concern for developers, insurers and investors. It is a prudent step to ensure that a robust risk assessment includes PFAS.
PFAS can be effectively managed through existing framework guidance for managing risks from contaminated land in the UK. This includes the 2023 guidance Land Contamination Risk Management (LCRM), as well as industry codes of practice for reusing materials during redevelopment. These approaches support risk-based and sustainable management solutions based on the suitability of the land for end use and so should be proportionate to site-specific risks and constraints.
Depending upon site-specific conditions, several pathways need to be considered to assess potential upgradient sources. PFAS migration in air from industrial or commercial sources can influence soil or groundwater a great distance from larger sources. So consideration of the site and it’s context with surrounding area needs to be included.
Conceptual Site Models
A robust, site specific Conceptual Site Model (CSM) remains the basis for assessing potential risks. It is necessary to have a detailed understanding of the topography, geology, hydrology and hydrogeology for all of the sites and surrounding area that may impact the location. In addition, knowledge of the types, properties and fate and transport of PFAS along with biotransformation of precursors are all crucial aspects in conceptualising PFAS sources, pathways and receptors.
PFAS Mitigation & Remediation – The Third Step
If the site investigations reveal PFAS contamination then Stage 2 options of the LCRM will be followed
If you have reached this stage, then a decision has been made to remediate. Remediation is the action required to prevent, minimise, remedy or mitigate the effects of the unacceptable risks.
Follow this stage to establish an appropriate remediation option.
The contaminant linkages identified through risk assessment now become ‘relevant contaminant linkages’. They represent the unacceptable risks to the identified receptors.
There are 3 steps to follow.
- Identify feasible remediation options.
- Do a detailed evaluation of options.
- Select the final remediation option.
If you have progressed straight from a preliminary risk assessment make sure you have sufficient information. This includes the detailed information required by the generic and detailed quantitative risk assessments.
For step 1, you will identify and produce a shortlist of feasible remediation options. Make sure the site information is up to date, set objectives and plan for any regulatory controls that may be needed for when remediation starts.
In step 2, you will evaluate the options to decide which are the most suitable for dealing with each relevant contaminant linkage. You use options appraisal evaluation criteria.
You may need to combine options and consider how this would work in practice.
In step 3, you will select the final remediation option. In some cases, selecting only one option may not be practical or sufficient. There may be more than one or different types of relevant contaminant linkages. The final option you select may be single, multiple or combined. These are taken forward to Stage 3 of LCRM, where the remediation strategy is developed.
At Earth Environmental & Geotechnical Ltd. we have extensive experience of remediation designs for Contaminated sites and will work with you on a cost effective pragmatic solution.
Contact Us now to discuss your project
More About Earth Environmental & Geotechnical Ltd.
We have worked on a huge array of your sites, from former gasworks, Victorian reservoirs, sewage works, battery storage facilities, renewable energy projects, asbestos factories, electricity sub-stations, collieries, fuel retailing stations, airports, abattoirs, quarries, landfills, etc.
Our services have been used to assist in securing planning pemission and for the the planning and design of new retail stores, housing projects, renewable energy, windfarms solar projects, landfills, quarries, and the restoration of numerous brownfield sites.
We deliver, and take pride in, providing cost effective and pragmatic geotechnical and environmental solutions from our 8 offices in Bath, Cardiff, Edinburgh, Inverness, Stockport, Maidstone, Reading and Wilton.
All of our offices are run by highly experienced Directors, backed by degree qualified staff.
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Environmental & Geotechnical Consultancy Services Throughout UK
We provide a risk-based, pragmatic approach to the implementation of PFAS management.
What Are PFAS and Why Are They a Concern for Our Environment?
PFAS – perfluoroalkyl substances are also known as forever chemicals and are ubiquitous.
PFAS are a group of manufactured chemicals that have been used in industry and consumer products since the 1940s because of their useful properties. There are thousands of different PFAS, some of which have been more widely used and studied than others. PFAS are used in a wide range of applications from non-stick pans to fire extinguishers, pizza boxes to clothing. Most people are in contact with PFAS everyday, most exposures are relatively low. However some exposures can be high and accumulate in the body over time particularly in specific situations
Current research has shown that people can be exposed to PFAS by:
- Working in occupations such as firefighting or chemicals manufacturing and processing.
- Drinking water contaminated with PFAS.
- Eating certain foods that may contain PFAS, including fish.
- Swallowing contaminated soil or dust.
- Breathing air containing PFAS.
- Using products made with PFAS or that are packaged in materials containing PFAS.
Research has highlighted that this PFAS group, more commonly known as forever chemicals, is linked to a range of health issues including testicular cancer, fertility issues and developmental defects in unborn children. The current legislation on PFAS is changing as more research and information is available so having an understanding of the risk of PFAS on your development site is important.
At Earth Environmental & Geotechnical Ltd. we work with our clients to ensure there is a detailed understanding and risk assessment of all development sites. Consideration of PFAS risk should be included at the earliest point of site investigation and included in the Phase 1 Desk Study
More about Persistent Organic Pollutants and PFAS
PFAS compounds are fluorinated substances that contain at least one fully fluorinated methyl or methylene carbon atom. PFAS are a board group of more than 6000 synthetic fluorinated organic chemicals . They are particularly useful for repelling water, grease and dirt, as surfactants (a substance which tends to reduce the surface tension of a liquid in which it is dissolved) and are thermally and chemically stable.
The carbon fluorine bond is extremely strong in PFAS compounds which provides some of their characteristics, but also gives challenges and persistence in the environment.
PFAS are:
- Extensively distributed
- Water Soluble and very mobile especially short chain PFAS
- Bioaccumulating in plants and animals
- Do not readily biodegrade so persistent in the environment
Through UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) The Environment Agency and the Health and Safety Executive (HSE) examined the risks posed by PFAS and develop a ‘Regulatory Management Options Analysis’, which will set out further options for managing the risks of PFAS chemicals. Last year the government published environmental risk evaluations reports for PFAS https://www.gov.uk/government/publications/environmental-risk-evaluation-reports-per-and-polyfluoroalkyl-substances-pfas
This consisted of nine reports on the environmental hazards and risks from certain per- and polyfluoroalkyl substances (PFAS) being made or used in the UK.
This work contributes to the UK Government’s action plan to address concerns arising from PFAS by providing an informal assessment of the available data to gain a better understanding of the hazards, exposure and risks these substances may pose to the UK environment.
High levels of exposure to certain PFAS have also been shown to cause harmful effects in humans and some have been declared to be ‘Persistent Organic Pollutants’ (POPs) under the United Nations Environment Programme (UNEP) Stockholm Convention.
Current Research has shown that exposure to PFAS may lead to health issues including, reproduction, child development, cancers, immune response, hormone disruption and increased cholesterol.
The Environment Agency completed site assessments on a range of facilities including landfill sites, fire stations, water treatment facilities and military airfields.
The EA has assessed certain industries as high risk for PFAS as they involve production of PFAS or have/ had PFAS in fire suppression systems including:
- Nuclear
- Chemicals
- Oil & Gas
- Paper and Textiles, in particular carpets
- Mineral & Cement
- Food & Drink Industry
If you plan to develop a site which is or has been one of these high risk locations then a PFAS Risk Assessment should be part of site assessment and due diligence.
PFAS concentrations can also be high on locations used for Fire Fighting training or areas where foam fire extinguishers have been historically used. Research has also shown elevated PFAS levels in agricultural land where paper pulp containing PFAS has been spread to enrich soils.
