AEG EVENT 2/22/24: PFAS Chemical Manufacturing

DINNER MEETING ANNOUNCEMENT

PFAS Chemical Manufacturing Air Emissions Sites

Thursday, February 22, 2024

At the Clarion Hotel in Somerset, New Jersey

Jeffrey Andrilenas, R.G., Partner, The TBLS Group

PFAS Cycle

ABSTRACT
Air emissions of perfluoroalkyl substances (PFAS) from manufacturing/industrial plants can impact the environment and are a relatively rare type of Conceptual Site Model (CSM), that environmental geologists should be aware of when doing due diligence and site investigations.  The more common emissions sites that can cause environmental impacts onsite and offsite often are associated with battery recycling and/or metal smelter sites. Rarely do these sites cause significant impact to groundwater although they often involve significant soil contamination risks to surrounding communities due to heavy metal contamination.
 
Where PFAS compounds are used as part of manufacturing processes they can become entrained in air emissions processes, exhausted into the environment, and spread by prevailing wind patterns over large areas requiring inclusion of additional media such as ground and surface water in the CSM. Some famous sites where this has been documented to have caused impact to drinking water systems include the Hoosick Falls New York site, Bennington Vermont, Manchester New Hampshire, Solvay West Deptford, Chambers Works Carneys Point NJ, Washington Works West Virginia, Fayetteville Works, North Carolina, 3M plant in Belgium, DuPont plant in the Netherlands, etc. These manufacturing facility sites are rarer occurrences of PFAS versus more common sites related to AFFF (firefighting foam) usage sites, although AFFF manufacturing sites may have the same issues.

PFAS from a manufacturing site source could be distributed in the air media, and land on a variety of sensitive environmental medias, such as surface water, wetlands, soils, tidelands, and migrate to groundwater, sediments, drinking water, and biota, that are within the aerial deposition zone. Concepts of background can be quite difficult to determine. Today one cutting edge of impact to various medias includes the concept of Natural Resource Damages (NRD) liabilities/impact. In fact, NRD monies have already been collected in 2023 for this PFAS air emissions source in New Jersey at the Solvay site, and earlier elsewhere in the US including in 2019 in Minnesota. Interestingly, in 2022 the State of Minnesota began its first evaluations of air emissions around 3M plants, after they had already collected settlement money for groundwater NRD.

BIOGRAPHY

Jeff Andrilenas is a registered geologist, hydrogeologist, and engineering geologist, who has been practicing since the early 1980’s. He began his career at Golder Associates at the Hanford Nuclear Reservation and later at AMEC in Washington, Oregon, and Alaska. From 1986 on, Jeff has predominantly worked in the environmental field. From 1989-1996, he was a North American Principal/Regional VP and did work both in the US and internationally, including a two-year stint for the World Bank teaching US environmental practices in the Republic of China. Subsequently, in 1997-1999 he was a Remediation Specialist at BP Oil’s West Coast Environmental Management division. From 1999-2005, he was a Senior Environmental Consultant at AIG Environmental, specializing in monetizing CERCLA, sediment, and NRD for underwriting & claims risks. While at AIG, Jeff was a member of the Washington State Governor’s Panel on Area-wide Air Emissions (Pb/As) from Smelters and a member of NOAA’s NRD Cooperative Assessment Program Guidance Committee. From 2005-2012, he co-founded and was a Senior Vice President at Bluefield Holdings, the first NRD Banking Company in the US, (a VC-funded startup which is now owned by a NY Pension Fund.)

Jeff has been a partner at The TBLS Group in New Jersey since 2013. He specializes in Environmental Liability Valuation, NRD, and litigation support. He sits on, and is a voting member of, several ASTM E50-04 Investigation/Remediation and E50-05 Corporate Risk Management Committees, including 2 PFAS Committees (PFAS Analytical & Sampling, and the PFAS Conceptual Site Model.) He is a steering committee member of the Environmental Business Council of New Jersey (CIANJ), co-chair of the NRD Section, and a member of their Emerging Contaminant Committee. Jeff has been a frequent speaker at CLE credit programs in NJ, PA, OH, FL, & MA, for PFAS, NRD, and Environmental Liability Valuation including in 2022-2023 at EECMA, EBC Round Table, NGWA, NJ Bar Association, CIANJ PFAS Summit, and BCONE.