Webinar Date: Wednesday, May 17, 2023
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Good morning, everyone, and welcome to our seminar, sponsored by Oklahoma State University co-operative Extension Service and Try Hydro. We'd like to welcome you today to updates on PFS and the environment. Next slide, please.
OK, most of you saw yesterday, we sent out the agenda, so, we're just giving you a little bit of a refresher. Well, have our full morning and a full afternoon with some breaks and lunch and created. My next slide.
There's our afternoon for Everybody's Perusal OK, Next slide.
So, my name is Amy Blyth and I'm with Trihydro Corporation. I am the event co-ordinator. So you all need anything online. Please make sure and contact me via the question panel. To get started, we're gonna go over a couple of housekeeping notes and taps. We are recording this session and it will be available after the webinar, along with a PDF of the PowerPoint slides. So you should receive an e-mail within a couple days after today's session with that information. For those of you online, you are in listen only mode. If you have a question, please submit them in your questions panel at any time throughout the webinar, and we'll address them as time allows. After the live Q and A, at the end of this, or during the each session, what, You'll have an opportunity to ask your questions in person first, and then will moderate those online.
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Flip the slide.
Very proud them up and went into the next one. Could be, There we go. So, those of you online, you're all in listen only mute mode, excuse me, you would be immediate muted throughout the day, and, again, just make sure there's an example of where the, or what the control panel looks like and where your questions panel is, exception. So, with that, let's go ahead and get started.
I'll pass it over to ...: thank you. Amy was wanting to go on. ..., Oklahoma State University Study with attention, OK.
So just a little background about our program, we provide solid waste management around tribal communities.
We are funded by a grant from the USDA. So, we know tons of trainings and workshops and outreach.
On various topics, we started venturing into 20 20.
And we're happy with plasma sheet, operation. Debbie, amazing. Amazing button as though. We're happy that we've got to do this again.
We do it every year, so Amy and the rest of the team, thank you so much.
So we launched high, go ahead, introduce our first speaker. She'll be talking about the Real Estate CPA option.
So, our next speaker will be coffee.
She is of an Engineering Manager of the Water Quality TV show of the Oklahoma Department of Environmental Quality.
She's registered as a professional engineer in the state of Oklahoma and a member of the American Nation, 28.
Well, good morning everybody.
She said my name is Kate Coffee, the Department of Environmental Quality in the water quality division and I work with flex program.
I plan to just briefly describe some of the recent action related to keep as an ad spend most of our time, talking about the reset lady published, Propose Paypass Drinking Water.
I hope you all are just riveted on turkey, like. That's just at the time.
I just wanted to give credit to others. I've been participating in webinars with AWPA.
Or, I should say I've been watching them participating in that way, asked why the epi center at EPA, and, what I'm going to be talking about this morning is information that I've cleaned up. So, I did want to give credit to that.
So, we're going to skip the usual background, because I imagine everybody in this room has heard about PFAS. It's been around for about 70 years, or something like that.
It's entered into commerce, it's widely spread, it's used in many, many products that seem essential to our lives, so we'll start with a background that deals with Health Effects, and ABA. Has indicated that exposure to P fast over a long time, may lead to several negative effects, negative health effects on pregnant people, and developing babies.
It can weaken the body's ability to fight, to seize the inner sides.
It can decrease the risk of some cancers, and cause liver damage.
It can elevate cholesterol levels and that can increase the risk for heart attack or stroke or sedentary reasons.
Boy, we're looking at some of the work that EPA has doing.
Some of the recent actions, OK, well, except for this first one, there are many, many actions the EPA has taken.
During the past approximate year.
The first word in September of 2000, when EPA drafted, analytical, or EPA issued its draft Analytical Method 16 33, that is for 40 P fast in wastewater, surface water groundwater, soil biosolids, sediment, landfill, leachate impish tissue and it's a really important message. I think it's still in draft form and people are really looking forward to it the final April of last year. EPA published Draft Analytical Methods 621.
Zirbel organic flooring and water samples and for screening for sepsis is containing carbon fluorine bond, including PTS.
In May of last year, EPA published draft recommended aquatic life ambient ambient water quality criteria are our MP bus and I believe, that's still in draft stage.
In June of last year, they released the Drinking Water Health advisories under the Safe Drinking Water Act.
They released enter of updated health advisories for ...
and final ha's for Gen X and P, FPS. I'll just talk about this briefly in a minute.
August of last year, EPA proposed for designation of the fast as hazardous substances under 2%, or surplus, and the agency, a comment on that, I believe that that is still a potential for.
So, maybe done in December of last year, EPA proposed a rule to improve reporting at P fast in A toxic release inventory.
The TORI, including elimination of an exemption for de Minimus concentrations.
I think, originally, if you had something like £100 or last word asked to report well, that de minimis exemption has been removed.
December of last year, EPA released a memo to provide guidance to states under in p.d.e.'s permitting program to restrict PFS at their stores.
And it was, in other words, at the discharge point and in January of this year.
The unregulated contaminant monitoring, rural fides sampling or 29 P fast and lithium began nationwide.
It's going to continue three years.
It'll continue through 2025, and this year, the smaller systems, less than 10000, for example, And I might cause this for a moment.
two: To just let you know, that this past week, Really, sir, We received our first verification.
That one of our smaller, public water supplies in this day, you receive a sample result.
That was detectable, it was 9.4 parts per trillion, NFP fast.
Uh, it draws on the surface water source, And so that doesn't mean this is just data, at this point.
It doesn't mean that there's anything regulatory going on, but it's sort of nervous that there may be issues later, layer down the patch.
Let's see, March of this year, EPA proposed a national primary drinking water regulation, are six PJs, including the fast Gen X, P S B S P F H X S.
and ... under the Safe Drinking Water Act, and that's what we'll be talking mostly about today.
In April, EPA published their advance notice to have a rulemaking related to potential development of future regulations under Stark Law are seven additional PFS besides our MP fast and not just that you read that on the screenings, DEQ is in the process now of preparing comments on that advance notice.
OK, so the two actions that are going to be discussing this morning will be first, the GQ at A Health advisors very briefly, and then the ... Festival.
So, these were the Drinking Water Health advisories that came out. These are non regulatory, and they reflect EPA's assessment of the best available peer reviewed science.
Health advisories are intended to identify the concentration of chemicals in drinking water at or below, which adverse health effects are not anticipated to occur.
The interim updated Health advisories for ...
Class Superceded, EPA's 2016 Health advisories, which were 70 parts per trillion, either individually or taken together.
These are much slower as you can see.
The final, The final advisories were released or genetics camel chemicals, ....
So here we go.
These are the chemicals, the six that are being regulated.
Well, it's propose that they be regulated in this proposed rule, and if you look at the ... or ...
zero, because the critical have effect, it's listed as cancer.
The maximum contaminant levels for each of those is 4.8 parts per trillion, which you, if you remember, the previous slide, is much larger in magnitude.
And it's really based, I think, at this point, on the stability of labs to analyze or dose, chemicals.
An interesting part of your site is the hazard index designation. This has never been used before in drinking water.
I understand, for my land protection brands, that it's been used for things like, say, pretend.
It's never been used in the drinking water arena before.
It's EPA's method trying to look at mixtures, and regulate these as mixtures. And I'll talk more about that, in a minute.
As you look on the left or right hand side, you can see the different effects for the four that are part of the hazard index.
one of them is regulated, critical health effect, liver attacks, one for developmental effects and two for thyroid Effects, you can see they're not the same throughout.
Just pausing again for a moment to give a little perspective.
We hear each day how how there are more and more of these chemicals that have been identified, I think.
The last estimate I heard was 9000 plus of that.
There part as part of the regulatory process, EPA has picked out 29 to include in unregulated contaminant monitoring to test for.
Now just a side note, usually they use the EMR testing is done before regulation is posed or comes into effect. So this is a little bit unusual. It's used to determine the rate of occurrence across the nation. And then that information is used to go on further with enrollment. So this is a little bit unusual.
They're regulating Stix.
The hope is that, while you read in their literature, that, the thought is that there may be other, Peter says, These six that will be mitigated in the process of mitigating these six.
There is another part, is rulemaking process, which they caught or six year review process, that every six years they look at rules, decide whether they be updated, changed, modified it true.
So, there's a possibility, with time that there may be other PFS regulated.
OK, let's just look quickly at the index, uh, this is a sum of fractions.
And there's four fractions, and each fraction in the numerator has the level of pathos, that was measured in the water.
And the denominator is the highest level determined not to have at risk health effects.
So you can see in the equation at the bottom, the 10 part per trillion was Health Advisory level for Gen X And the 2000 points, zero parts per trillion was Health Advisory level for PSP. Yes. Now, the derivation of the attitude was included in the P&L and it's way beyond me to be able to explain that But those are not health advisory app numbers.
This is an example calculation to just get a better idea.
Example water quality is listed in the bullets and then there's those values instilled in this equation.
And when you add up as for fractions, you come out with Health Index of 1.2.
So, that is greater than one.
That is greater than the MCL for these four considered as it were.
So that just kind of gives you an idea of how this works. one thing to mention in passing is that this equation assumes that these are our attitude and their effect.
We didn't notice on that table.
we saw earlier that the critical health effect is not Safe Science Advisory board, and they reach you.
This accepted it as a default method for looking at these mixtures. But at the same time, suggested that export data become available this DB just revisited.
OK, just quickly monitoring requirements, the water gift the situation gets a little bit cloudy or a little bit complicated when you get into monetary, But let's just take a stab at some of the high points.
Uh, this proposed rule applies to the following types of public labs, community systems, and those are ones that serve 25 people, or 15 service connections, minimum, all year round. And that would be like a city or dormant or mold trial or garden.
Uh, the non transient non community system serve 25 people. They're the same people, at least six months a year.
An example would be a school that has its own water system like its own.
This rule does not impact the smallest type, which is the transient non community.
That's a system that serves at least 25 people, 60 days out of the year, but they're not the same. So an example of that would be a gas station with its own wires.
The analytical methods used for this rule will be ABA Method Slide 33 and 5, 37.5. These are the same methods that are used.
And you see on our side, consecutive systems are not specifically named in this role.
Some people assume they're included. Some people assume they're not. So clarification is be asked to the EPA on that point.
The deal is that if there was, like a rural district that was purchased the water and secondary system is one that doesn't have some stops, Purchase the water from another system, like a raw water district, just sideswipe through a meter, So that were tested and it was out of compliance for PFAS.
It really doesn't have a lot of control over the situation. So the solution to the problem really would fall to the parent system. So that's another thing that's sort of being examined in context are being made with EPA about Apple Watch.
The monitoring requirements will be for every entry point into the distribution system.
So if you have 10 wells, each one entering at a separate point of the distribution system. Each one of those has to sample.
The system might want them all together and make a composite sample and save money by the EPA is not allowing for that.
in the case to disrobe.
The initial sampling will take place during the first three rules after this rule.
Becomes final, Let's assume, for the purposes of this, that this rule will be published and will be fine all by January 1, 2024. So that three year period would be 24, 25, 26, and January 1, 2010.
In that case, each system would pick up one year in that three year period, and they would take either two samples, or four samples, depending on what type of system they are.
And I'm not going to go into the details, but you can see that it depends on whether your surface, a brown bag, or whether your little systems can use the EMR data, if they have.
All right. This is where it gets even a little bit more in the weeds, but we'll try to just, you know, not get too bogged down.
After that initial monitoring, those results are available to help set up the sampling frequency for that system as it moves forward. So let's assume that we're now in January 2027.
We're ready for compliance monitoring.
So, if these systems, uh, how do I say, if you look in the left-hand column, you can see that there are trigger values.
And so, if system averaged if the initial snappily average greater than or equal to 1.3 park or tell you for resale at the same thing for each class.
And if the health index is greater than or equal to weight 3, 3, they keep monitoring quarterly monitor quarterly.
On the other hand, if those samples, or the compliant stabling they undertake, show that they fall below those values, then they're considered reliably and consistently below the MCL and they get to do, we do smart monitoring, and I'll go into those details theater.
That's all on the slide, and you can see that, that's one interesting thing about this, is that, each entry point to the distribution system, maybe on a different compliance monitoring schedule, uh, some may be in compliance stuff, maybe outs that may be above, that may be below.
Yeah, And also, another interesting little thing is that, if you have your rent an annual average, low, that trigger, you can get on reduce monitoring, but it only takes one sample that's above that as you go back to regular monitoring.
So from the point of view of the systems, and also from the point of view of the regulatory entity trying to track all this, this, how does it start about an issue?
How often are we going to be going back and forth, and how difficult will it be to really keep track of all this, and keep up with all this?
There's something else dimension here, which is that 1.3 part per trillion is below the minimum reporting that well, yes.
The question would be, would any particular lab that was receiving samples be able to tell us at the state level? Maybe start maybe not.
The four was chosen because it is a practical quantitation level reporting.
So going beyond that, are below that for this purpose, there's another let me say another point gets racing class aye Among people who care about these things and are are talking about Bee squirrels.
So how did we how did we calculate determined violations?
That compliance for the MCO's is determined by calculating a running annual average at each sampling point.
It is, ... result is below the practical quantitation level for the monitored PSAPs.
EPA proposes to use zero to calculate the running annual average.
This is different from their approach to the monitoring, increase and decrease.
So that's then also another barrick variants that it is racing patch.
Um, public notice, the Consumer Confidence Report must include levels or any of the six regulated PFS that have been detected, and it must also have to the hazard index. when there has been a detection of any, of the four PTS included in that index.
The public notification requirements are violation of any of the three MCOs. Would be a Tier two violation. That means it's considered chronic. And some education would be required no later than 30 days after the system parts.
That's sort of know, like, DB keys, if it gets at tier two notification parameter.
So time, I agree, implementation, we have already kind of alluded to this that we expect that the rural or EPA has status to expect that their rule will be published and find out by the beginning of the year.
And that's a three year initial period with, and January of 2027, uh, see if there's anything else I have forgotten to say.
Oh, yes. So, I think I've heard EPA in their presentations, and they're kind of thinking that these three years, three additional years, I'll give a system and an opportunity to know where they stand. Are they going to have an ... problem? Or not so, they can start planning and constructing and preparing to meet the requirements. The reality is that some systems may not sample early. In that three year period, they may wait.
And also, even if you know that you have an issue, it takes time to get funds together, to get a project together, to get a contractor to get construction going. So, it's probably going to not all happened within that three year period there. There is a provision in EPA's rules to allow a two year extension for those that are doing construction.
So what are some of the challenges? What communication is a challenge?
The hazard index itself will be a challenge. Because we will be half, we will be trying to communicate this, to people who've never used this before, and you're not were not familiar with it. It will also be a challenge that we will be having ...
results coming back during the time, that people are hearing about this role and knowing about the health effects and so on. There's also the communication issue and explaining PFS exposure to other sources.
There's a lot of other sources besides drinking water to which people are accessed.
Lack capacity can be an issue. Will there be enough lack capacity?
The cost of treatment, especially for small groundwater systems, that have never provide treatment, are only chlorinate.
This, this could be huge for that systems, There operator expertise will have to be upgraded, Their expenses for their water will increase, and so on. There will be limitations related to availability of engineers and contractors. To do design and construction.
We're already seeing that this is an issue now. With so many people wanting to undertake projects all at once.
Treatment for PFAS and then residuals and that will take time.
So, EPA Prepares is the following as ...
Best Available technologies GHD or granular activated carbon.
It is granular activated carbon anion exchange, high pressure membranes that is IO in an S reverse osmosis and nano filtration. They also are talking about non treatment options, like getting a new and contaminate, sourced, maybe drilling any well in a different area or purchasing water from an uncontaminated system.
Some of the challenges related to treatment deal with the time and expense for bench testing and pilot testing.
People never want to slow down to do that stuff and spend the money that it takes to do that.
Bench testing helps, and especially in media comparison and pilot testing helps in predicting runtimes. How often you're going to change out your media and so on.
There will be simultaneous compliance issues, such as the Common Rule revisions and erosion control, and there may have to be crashing control studies that systems are talking about changing their treatment.
There could be a silver lining to this in that the same thing that removes PFS may be helpful in removing the total organic carbon that is responsible for DVT production.
So that when when passing note?
Management of treatment residuals this is a big issue. It always is. and especially with TFS.
Uh, EPA indicated in the preamble to the rule what they consider the most likely management actions And for TAC, reactivation of thermally, um, for ion Exchange, resin, incineration, and of course, landfilling is often talked about with constituents as well.
The RO and I've concentrate if it's discharged and surface water or sanitary sewer sewers, but just be moving too fast. It'll still be there and it's just going back into the environment again.
So unless that plan to take all that or somehow deal with it internally, it's sort of an obstacle to choosing this is kind of treatment for PFS.
EPA in 20 20, issued their interim guidance on the distraction and ..., and materials containing substances that they started as hay, There was a lot that was left done and they said that they will bring out a revised version later in 20 23.
The dispatch, the oxygen options for gash, and ion Exchange Resin that were in that guidance were landfilled.
Sure, so, just as a note, another note about the serco designations.
Concern has been expressed that hazardous substance designation for certain PFS under stark law may limit dispel some options.
There may be some landfills, for example, that mall want to accept, that that's that media and concentrated waste streams and so on, or they could charge more.
So that's another issue related to PCAST, too.
With that, I will conclude, I want to say, once again, this rule has only been proposed, and anything that we've talked about today is that change. You never know what you're going to do with the trail. And they are pretty secretive about it. They keep it pretty close to the vest that we'll see what happens.
If you would like to make comments, the docket is open until May 30 systems are not required to do anything. now.
We expect and defy the row will be out by the end of this year, and that violations can potentially occur after January.
Leave that up to the moderator Amy? Amy, do we have any question online?
Not yet, but again just a reminder for folks to submit via the questions panel in your goto Webinar tab.
OK, so I have one question for you. OK, so we Debbie funding for public water supply demand issue.
We have the formula applies to a patient of Great, thank you for that question. That's a good question.
I thought that might keep that, so I talked with our State Revolving Fund manager, Take a sea bed, and Todd just relay to you what he had to be wasted.
DQ anticipate receiving approximately $11 million per year over the next four years.
And that's L many, provided we are able to demonstrate the need and use for that.
For the emerging contaminants, many, all these spends less can provide it as a startup grant to communities that have eligible projects.
A minimum of 25% of the funds must be awarded to communities that meet the state definition.
Disadvantaged communities due to the lack of PTSD projects in the state, We don't have a lot of testing.
Oklahoma is currently targeting systems, Manganese issues, to use this money.
Anything that's going out, any of it you see, this is considered an emerging contaminants and the money can be used for that purpose.
Additionally, the State can use portion of those contaminants fantasize about that capacity. There is one thing to note.
There's a lot of money out there for construction plants, a system, like. let's say it's a small system.
If it's underway, it's trying to maintain its operator capacity, Equipment breaks down, they have to do test the test expense side.
SBIR money does not pay for that, it pays usually just right.
Thank you for that class. Thank you, Jay. Let's give a round of applause.
one thing I'll say, classroom is right there, and in addition to the very amazing, because we have, We also have all 10 year, old police also. Also.
He's alive, so if you have questions, please feel free to apps.
We have excellent. Answer your question.
So, OK, our next speaker will be talking about the legislative and regulatory PFS explosion.
What has happened and what to expect?
Soul pays me start.
Xiaomi phone, you definitely generate the ink, pro and deadly, OK, OK, see?
The Oklahoma City office throughout his career, legal practice has been focused on, it has extensive experience addressing the nation.
Like building groundwater birthdays on a O as well as sharing mediation technologies These efforts have required ecstacy interaction with Slava Retraced throughout the US.
Many teach the PFS estimated he also advises clients on ethos regulatory developments of litigation.
So, welcome, Donna.
And you can tell who the technical person isn't. It's not that. They can see all the other side.
Just, Yeah. Just like, It's just like a team to be. All right.
Then they put two people right up your throat.
There's a number of folks in the room, obviously, I know, and certainly have enormous respect for a lot of technical people like doctor Fei fei Li even. Destroyed. I want to say first of all, thanks. To do, to try hydro and, and obviously, I work closely with Andrew on a couple of things.
So appreciate the opportunity to come and speak to you all this morning.
Probably as good a panel on this topic, as I've seen an entry, present company excluded, of course, But That's really, really talented, folks.
Most of that in mind, though, and obviously you've heard from doctor Coffee already and and doctor Reed, a doctor can, as I call him, doctor Adrea, Damon Rich or remove and Danny.
Really, really great group of people. So glad to be here.
I wanna mentioned a couple of thoughts about this presentation because I'm gonna be running through some of these slides really quick, is only have 30 minutes.
Um, my slide deck.
And I've got to be honest about this, uh, interested in complete disclosure is a compilation of some thoughts from Tim, so wacky at my office who's one of my partners. And this is lovely spouse that currently is here.
So, she's gonna hold me honest on those thoughts this morning, but our firm has really focused on the P boss issue.
We have met folks with Masters, Environmental Science. We've got engineers at our office that are involved in litigation on these issues.
So, we spend a lot of time and my focus this morning is not going to be so much on just the regulatory side of it.
Although a lot of my slides will look familiar to those that pay presented and I'm gonna scoop right past those and give you some thoughts about where the policy issues are going.
The battles that are being fought in Washington, and I do spend a fair amount of time up there in contact with several industry groups and in Washington, and there is major major battles going on around how this is to be regulated.
We're in Oklahoma, the cows out of the barn, so to speak.
Litigation has been going on now for some number of years and I'll talk about the common law theories, things that people are having to deal with around, around those issues as well.
A couple other things that probably should mention and again, a lot of this is going to be rehash from from Kay Slide deck and I'll move through those.
We were visiting earlier, Andria, Danny and I were talking about Danny actually mentioned that I think it's a good analogy.
going to be similar to what docs and wants policy perspective? And, you know, it was such a hot issue.
It still is an app that aside for a large site in Iowa, where we've got several really problematic docks and gardeners.
We're dealing with them, and they're very concerning.
The boss is at this forefront now.
And I know I'm talking to doctor Reed multiple times they're certain, uh, molecules related to the PEAT bogs family that are more concerning that are similar to the datsun discussion.
So, no, it's going to be interesting to see where this gets, But I can't say this.
Having been a lawyer, and I teach a class at the law school at ODU, once a year.
Environmental law class, and I'm proud to say, a young tech person who went to law school.
She has written an article. She worked for the aspect any last summer.
And she wrote an article, is going to be published in the Oklahoma Law Review about P Boss.
Which I find kind of fascinating. You know, law schools like to just focus on these Moyer types.
That's kinda nice to have the technical folks sort of grab and the Law Review articles and taken over and you know, when you scroll up to three of them, I love that.
So so this is really percolating down into every part of society. I think at this point are under way. It's nothing that can be stopped In my 38 years.
I think it's probably in the, three, maybe two issues.
Environmental issues, from the legal side, in the last 40 years, we're not gonna get away from this.
It's problematic. It's got huge implications.
Or certain companies in this country.
Um, depending on how the regs get adopted, if it gets super funded, the substances become hazardous substances under super fun.
Uh, I can tell you that in my experience, having worked for a very large public company, Superfund Sites all over the country.
Which fat seven, $800 million in West Chicago playing a low-level nuclear material.
And, but I don't think any of that is one location.
I don't think any of the things I've seen that prepares for the cost and policy implications of people. So I know I'm probably preaching to the, to the choir on that one, but. But.
Very, very important to just understand about that issue. So I'm gonna work through these slides really quick because 30 minutes for this lawyer. You know, it's kinda like creature talk. And in all of y'all are sitting in the back row back.
Just like on Sunday morning, I guess, these slides again. a lot of this is gonna look familiar. I'm not gonna read these to you.
I'm going to make a few comments about each one of these.
Again, doctor Coffee made some comments, know about where EPA is at in the programs that are coming forward.
Some of which are already out there inactive, and I'll mention a couple that are still taking public comments on the thing I want to point in this slide, look at the very last bullet, Use enforcement actions to help manage P false risk.
And, the last slide at the whole deck, I'm going to talk about the Cures uh, settlement, It's in order that BPA entered into the facility back East.
We have no regulation, right?
Currently, no regulation.
But we've had litigation hundreds of millions of dollars in settlements already, three M and people around the country, towards Dupont.
But the question, especially representing industry, people, are starting to ask me as well, Know, even though there's no regulation, something there in the States, no, you're not.
We know, we know this, particularly the regulators and the grout.
But there are broad definitions of what constitutes pollutions and Oklahoma and other states that I've worked in, 41 states.
So, um, if if state or federal agencies want to get at this issue, there are ways to do that already.
Now, it's not as good as if they had a whole suite of regulation that's coming.
But, today, there are opportunities for EPA to get add at this issue.
Now, the thing that that I should say at the outset, too, that's important, is correct, or all my slides.
In the floor, this is such a huge policy biked.
What you've seen in some form, this this whole area exploded around 2010 to 20 12.
It's been around for a while. Having been involved in, as many of you have multiple administrations in Washington.
This, this issue, has been blowed a bit.
It slowed the Trump administration, but it did not stop.
And think about this for a second.
Um, there were a lot of issues, and I'm not making a political statement one way or the other, because I have to deal with all of this administration's whether those are ****.
Uh, the thing that is important, I think, to understand about this issue, it won't go away.
They're things that every administration, they follow a Democrat Falls or Republican, or vice versa, they want to get rid of certain concept, right.
This is not going away. It may slow, but it's not going away ever, OK?
We need to need to certainly understand that.
The other thing is, though, it is nobody agrees on anything in Washington, right?
We all know that, which raises the difficulty in getting a common sense approach to the issue.
We're just talking about the federal government at the very tail end of this, but I'm also gonna mention the states.
We've got several clients there have been calling us, and the pulse have accelerate over the last year where they're saying, oh, well, we're doing business in May, and I'll get to that in a second.
And what do we do, because they adopted a Statute in Maine that is addressing this issue for intentionally using ... materials and products?
And I can tell you, when I last checked, there were the the requested exemption listed, the law that became effective, January one this year, was 35 pages, single spaced, and it's a who's who of America corporate America.
Because even if those companies did not place P foshay their product, they'd have to make sure that not their suppliers, intentional ESP boss and the product as as a component.
I mean, it's a very dicey, difficult situation. So I don't want to get ahead of myself as I'll come back to that. But just think about this. It's not just the Federal Government that we've got to deal with. You also now have 50 states. And some states have gotten extremely aggressive.
I mentioned May, after the 60 minute report on milk contamination in cows, then Manges really took off on this issue.
But I'll come back to that so that the policy implications of this are are difficult they're going to be really hard to overcome.
But I'm convinced that that things are going to happen I will say this, again, is the upload the State President Biden is re-elected.
It's this area is going to just continue to accelerate if they gain another four years in this area.
My prediction is, we're probably going to see a lot of the policy etched in stone at that point and also keep in mind, I know that any lawyers, I don't think there's any other words in here.
Any of these rules that EPA is putting out on the street, which Kate talked about.
Any of these rules before they become officially file they're going to get litigated.
And think about this.
The Clean Power plan was adopted in the Obama administration, the litigation on that just concluded about a year ago.
So this isn't going to happen fast either, right?
I mean, there's just too much at stake and some industries consider their very existence to be at stake as a result of these enrollment.
So, OK, very, very important to understand, just that policy implications. Well, I want to mention a couple of things about the analytical methods.
First of all, vast differences in my experience, over the last 2 to 3 years, and dealing with a lot of labs around the country.
Vast differences in the capability of laboratories.
And I see some people shaking their head, uh, and GPU folks.
I love, you know what I'm talking about, and we're talking about those from all the way from the big, huge names, bad, too.
Smaller laboratories, you have to be careful and make sure if you're sending samples to these labs, as a practical matter, make sure that you have folks in the lab that you can talk to.
We know most of the methods were originally used for water, but in the world I live in, most of those samples don't know. They're not just drinking water, right, they got sediment.
And so they've got all sorts of other things and the labs capabilities, the capability of these labs vary dramatically in my experience.
And, Danny is here from accurate amuck, my embarrassing, but I'll do it anyway and I told him this before.
Accurate lab is Stillwater has really, really done a nice job in this area.
And, we've used them extensively in that matter.
And, like I said, we used a lot of other leverage words.
And, I can stand here and say, you know, give tribute to accurate because they seem to have done a really nice job eliminate a lot of the uncertainty that it's been out there. So, Danny can talk about that.
A little bit more data, you can pay me later.
Enough enough about that.
The thing that I did, I do want to mention here.
There's obviously no concerns about health effects.
Most of the cases that used, you've seen files typically, at this juncture don't really get into the health effects so much as they get into the use of the common law theory.
And what I mean by that is, if someone, let's say, blue release, is that into the soil, and we all know that these pitfalls, substances, it runs to water, right?
It's spread to get through the soil to get to water and, uh, and so what you'll see in most of the litigation it's been filed, are claims based on nuisance. Trespass.
This is the old common law that came to us from Mario game that we all learned about in the first semester of law school.
Which I find a little ironic given the extraordinary, uh, complicated high brow, technical analysis, It's not everywhere, we sort of, at least the lawyers part, because we can't understand any of it. We just split back in and we use the basic legal theories at this junction.
Now, I'm gonna talk about super fun in a second, and that's Dracula.
That's what I call Draco, Suck the blood. All the live data, it gets a, hold up, we're gonna talk about that in a second.
But the common law theories have really been used and leveraged and have been very successful against him in several of these losses.
The other thing, I want to mention, how this public water system, and in K, and I were talking about this briefly before, we started.
You know, these cities that are loaded with cash, right?
Now, they've got no money.
And especially the smaller locations, they're going to struggle. Consistently struggle with whatever scheme is. And I don't mean that a negative sense.
But whatever regulatory programs are adopted, they've gotta have money.
Because the system simply aren't capable.
also mentioned the, you know, Granulated activated Carbon, which you might choose.
very best thing you can do to remove these substances, but it costs money and the technology is going to have to be developed for these large operating subsidies.
So, it's, it's not just the complexity of the policy, We're going to have to be budget.
We've got to fund these, particularly, the smaller cities they're gonna need, need some assistance in this area.
I'm going to run out of time is, as I promised.
Next slide. I won't get into the Pitfall strategic roadmaps.
You can read this.
Many of you are already know about this, but there's something I want to mention because I don't see it focused on this. And then, maybe there isn't.
Doctor Reed or somebody can correct me.
Doctor ..., I've actually talked about this.
What about air quality And that's a major area of expertise that I have getting through the years work a lot with big industrials.
What about air quality forever, chemicals?
At what temperatures residence times can these substances be thermally destroyed?
The preliminary information that I've seen is that it's a struggle for just a routine.
There are no rigid run of the mill incinerators.
But for purposes of this extension loop say there are: Do they have adequate residence time?
And, in thermal capabilities, I would suggest to you that most do not.
So, what if you're just bringing in household trash and you're combusting this material?
Um, Is there ... Senate, you got popcorn bags, you start we'll start off by shaking their head. Yeah.
So, we're focused on super fun and all this sort of stuff that's going to impact largely the corporate America industrial facilities, that sort of thing. But you also is just like under record.
You've got gaping holes for household waste.
Here you could be moving this material into an incinerator for example.
And you could be putting it out the staff, and where is it going?
It's landing in that many jar next door.
So I think that's an untapped or not an area that's not understood yet.
We need to look at, we need to explore going forward.
The other technology that I love avoids a lot with the industry, Submit kills, they can scrub and their, their profiles in the residence time are much longer, that may be an option, I don't know, all of this needs to be, needs to be studied.
OK, so, um, which we mentioned, no sir close.
... are the two substances are looking to list as hazard licenses.
And this thing has been out for comment, I can tell you, and the discussions I've had in Washington, this.
This is a, this is a to face the bar room, by fair enough.
It's going in Washington right now to try to either get it patched, get it etched in stone, or get it killed.
And we all know. It's a lot harder to pass something, and then it is to kill something.
So, it's, I'm watching with great fascination, this arm wrestling match that's going on in DC. As sun.
There are some companies and certain segments of industry that are more at risk than others.
And clearly, they're pushing out there and working hard to try to get some modification to, you know, specifically this rulemaking.
It's not just these two substances, I think it's clear EPA is looking at a number of other substances that are going to list potentially down the road. Again, I come back to not as a political statement but as a practice.
If the administration is re-elected, they're going to continue what we've already seen.
And whether you agree or disagree, that's just the reality.
So, you need to be mindful, mindful of that. And I want to come back to Circulate here in a second.
Actually, I'll come back to it right now.
Here's why this is why this is so important, I remember the movie, Dead Man Walking, but I remember that, maybe not. But we all know what the term means, right?
Um, uh, if these substances are listed, there are hugely broad implications.
And the thing I want to focus on is it would give super fun private parties.
The ability to clean up ethos and people on, on properties and recover compensation from potentially responsible parties.
And I know I'll get into, the legal easier. But two concepts that are really, really important about this. Talk for listing one strict liability.
So if you, if you took this substance to a location, if you, if you generated, if you transport it.
If you own the location where it's been placed, all these parties under this traditional Superfund analysis, strict liability firm, it's over urea.
If you've got a manifest with your name on and enlist a substance, boom, it's all your hand, OK. So now you know why people get nervous. Here's the other thing.
Let us say, doctor Reed and I take these substances to a location and shandy, uh, doesn't do so well and goes out of business.
I took 90% of the substances to that location doctor can eat 10% of those substances for that location.
Give a day, ED would be liable for 10%, right?
No, no, no, no, no, Dracula's showed up, he's got his cape bodies at the door. He's looking at ED, can say, Oh no.
Even though shandy's not around, you get the pleasure of paying for all of the cost, 100% of the cost, even though you may have only foot 10% of the substances at the location that require cleanup.
Just starting to get a little more clear now why Superfast scared a lot of people.
And, and again, probably, 25 or 30 Superfund sites and my responsibility when I work for a large public company.
And we had locations back East. We never all decide.
We never operated this site, saw one site close down in the 19 fifties.
We acquired a company that formerly of the site, didn't know any more, then the offer hit it.
Leave about last corporate entities.
An, eventually, eventually EPA got $300 million.
So this really does happen.
That's why this is, this is so important, OK, Couple of other thoughts.
Yes, There isn't it.
An advanced notice of proposed Rulemaking, ..., came out in April, EPA seeking input on seven additional substances and these substances include, well, there are salts and structural isomers, or some subset thereof, precursors, or a precursor, precursors a chemical that is transformed into another compound degradation, To repeat voting, foss, and seven other false.
False categories: Here's the, here's the importance, it and, again, other folks are much more depth at this, and I've learned from them what we now know what EPA notes, Some substances that are placed out there in the industrial marketplace, if you will.
Eventually, the gray to be concrete lost in people.
So, what the government, Federal government is, trying to do is, they're saying, Look, we know this.
And we're not going to let anybody escape. If you're if you have a substance that maybe has a particular name, completely unrelated, at least in terminology, from P falciparum, Oh, and over time, that, if rates to that substance, you're still live.
So, below, ground typing up around, like, the ... coming in on it, and, you know, I'm just trying to get out of the haunted house, or whatever it is.
So, so, we started with two, now, we're going to a little bit different concept, and, for lawyers, we're looking at, is to manage this thing, is not getting smaller, really, saying, is doing this, right.
Uh, and I personally am involved in a situation just like that.
So I've seen it This is real real-world stuff. Comments on this one, or this proposed rules are? Due June 12th.
All right? I'm going to skip over the Safe Drinking Water Act.
Do my last two slides, What are the states do? And this is the part that's really scary to me.
If you if you have a A a company, it operates in multiple states.
You gotta be concerned about this, or if you ship your products into multiple states, we could have, not just the Federal government sitting up here.
We got the potential for 50 states to adopt their different concepts of how they want to regulate all the way from Maine.
They had a statute become effective January one of this year and several other states that have also already gone ahead. And they are mentioned in the slide developed around a matching contaminant levels or MCL or their own particular states.
So this is gonna become a patchwork gang.
I mean, look, some people have said this has become the lawyers in Florida at the 2020.
I think it's been Kapila, the Technical Consultant Employment at 20 23.
Because this is gonna require so much in the way of resources to try to understand I'm being facetious. But it's very serious issue or brawl.
So, you can encounter different state cleanup standards, different things that you may have to do from state to state, to state, which is, why do you need competent technical consultants to assist in doing this sort of thing, if you don't have that capability apps.
Fast, I want to mention before I complete my presentation.
Some of you, if not all of you, may be aware, EPA, uh, entered into an order with the moores.
And, by way of background, dupont was one of the original parties who discovered these chemicals by accident.
I've heard great presentations on how that happened. You know, it was usually the atomic bomb.
All that sort of thing went into tat lot and it had a lot of uses.
Dupont spun off Cures.
Cures is now a separate entity and Kumar's, they've been in a couple of Frankenstein's with their own company.
What to do to us?
You can go out and read that data to live, but remember what I said.
Initially, we have no regulation.
So what does EPA did?
There's a facility that APS concerns about that had an entity be asked discharge from it.
And I'll just say this, and we can talk about a little bit later if you have more questions.
But in this document, which you can see, it's pretty thick, document, what they essentially did was usually authority under Clean Water Act, do require further investigation at this facility.
Are pitfalls simply follow?
There's always a way where there's a will, there's a way.
And the EPA has the will.
And, I'll conclude with this my read, again, that the Administrator of EPA, something, though, was the State Director in North Carolina.
Yeah, two primary objectives when he was in that position in North Carolina.
one of them was P Fox contamination to take bear river.
The Alluvial aquifer, which now there sampling thousands of groundwater wells that exist in the illusion.
So, you Secretary Reagan is now Administrator Reagan is now sitting in Washington.
And, and I personally think, even though I'm a lawyer, that represents primarily industry issues, we have to look at.
Regardless of where we end up on the policy, This must be thoroughly vetted.
But what we need to do is do a systematic way.
Disturbed if we have 50 states, they're also trying to regulate it, and I'll close with this.
For that reason, all states, California Governor of California, told his legislature, and folks that were trying to move ahead on this said, Wait, wait.
Let me move on this first before we do something, because it's gonna uncomplicate all of our lives in ways that we never match. So, sure, let's do everything. I don't know if there's any questions at a time when all that, I have three questions share. Any question?
OK, so what is the prediction all across the nation should Democrat or Republican? electorate?
I personally think that the issue is a start, but what you might typically think from the Republican side now, keep in mind that's on my law school classes.
Well, there was in the White House when EPA was established.
Richard Nixon who was a Republican, right?
You started going through this 990 Clean Air Act amendments to the President George HW Bush, kind of interesting, right? So if I make the prediction, I could be wrong.
I don't really think so.
Given politics in the country right now, I think, I do believe the gravity of the issue.
Again, is so profound what you might see as a slowing of the process, depending on who's in the White House.
But I do think if the Biden Administration stays in Office, you will see a lot of this really solidified.
And this is more than you all want to know, but usually if you're in an administration, you've got the first two years to get something done.
From a regulatory perspective, if you try to propose a, a lot of things after that two year mark, you just get bumped up against the next election cycle, So that's where we're at right now.
And that's why some of this stuff, there's question marks, all.
OK, thank you. My next question is, how will the state and federal government reach an equilibrium even the mass device security?
The problem is, under the Constitution, you've got States' rights issues.
And I think that, uh, what's probably going to see, is, some states are going to move forward, no matter what, no matter what, the Federal Government does. The other thing, there's an important concept.
The environmental laws, as A A general principle there are exceptions to everything, but as a general principle, if you have quality reg, water, red, states can generally always be more conservative or more restrict.
So, the ability to do that is already out there.
I think what's could impact the state is, and I know it will some, others I can choose, Probably they don't care, If you're not careful, you can be viewed as an anti business. Stay in it could actually impact jobs, and I think that's a bigger factor, probably pushing the policy sheet.
I'm not a lawyer, So I like the way that states, there's medical states, But the federal government.
And so it, that's the minimum, the minimum.
So at minimum, they happy, whatever they took equilibrium with just the federal government decides to do.
But states can go above it, they just can't go below it.
I guess, that questions, but, Conservative, like, you mean, like, just like, states, be conservative in the way that they dress flatlined, do, whatever Federal Government says, but they don't have to be more such, that, even state statutes that, say, you can adopt more restrictive requirements. Then the federal government has adopted to prevent their own regulators from being more aggressive if you are interested. I think.
I see a baby.
Right, thanks for that.
But I do think the critical thing here is, we're gonna get to some equilibrium on this, maybe 10 or 15 years from now. I don't know when.
Um, but I can tell you from industry perspectives sitting where I sit most of the time the question is, well, are you being becoming anti pistons?
And it means getting a lot of that blowback?
And just one question on account of federal and state job.
It is proposing hazard index dot gov slash yes?
How do you solve that fundamentally differently?
I think you need to ask doctor coffee, yeah, because she is an expert on that. I'm not real sure, Katie, you have a thought about that? I'm not. Real sure.
That that's what makes me uneasy.
And quite honestly, as a lawyer sitting in my chair, I'm getting calls from a general counsel who's operating it.
No, 18 states, and Maine has come up over and over and over now.
It is really, really difficult to try to buy somebody and the private sector.
No, not just the easy part is, OK, this is what's happening today.
But their management wants to understand where are the guardrails five years?
Where do we invest in this facility?
This is going to make this switch.
The way, you know, is there some reason, people aren't doing this all the time, all over the country?
They're making these valuation judgements, So I wish I had an answer, but I'm not sure.
Do you see businesses at all being friendly? Get on this?
Way to see what, until they absolutely have moster, my experiences, moster Pro Act.
But I'll give you a lot of a AAA firefighting fund.
Now, folks are are calling and saying, yeah, we've got, we've got these warehouses, there's 200,000 square feet and we got all this stuff.
We think we may have a triple F test that you need to first of all figured out.
There may be alternatives.
And so they're looking at that.
Second thing, what I'm saying, and I gotta admit I chuckle one of the levers and it was a big insurance carrier, sent a client a letter and said, please tell us all the pitfalls of materials that you use or you manufacture, and it essentially sprayed anything on your couch. I mean, I was like, that's it.
But so the question is, we're kind of elementary in some respects, but that was a year ago.
There, the insurance companies are now asking the companies and that's forcing to not negate their coverage, for example, or if you had a big fire, you released all this stuff.
You've got a triple F everywhere, it's running down the street, and I can tell you from my son the law's cathode and the fire department here in Oklahoma City.
They're very aware.
But let me give you one more example. Now, I'm wearing a good, doctor ...
is an expert on this, for sure, coming from Brian Employment America.
I've talked about so many times, and he has said, there are certain fires, you need a AAA.
Because you can not, the fire down that quit, and it can save lives.
Translated, two, to the transportation industry, specifically, aircraft.
And I know there are some in this room that can grow chapter and verse, about how much quicker and a triple F bomb will knock down a fire in an aircraft.
two or NaN means you live or die.
So, think about how we have to make these judgement calls.
Any other question?
Great, thank you, everybody.
How each industry coping with these rapid changes. Very well.
They are we. As a warrior we get a lot of questions.
I will say I think some are trying to are a little bit willfully blind about most folks are trying to understand where they go in most companies all.
They're reasonably conservative, They don't like to make major changes and less certainty.
There's enough of them using the hreflang example. I've had several others that were, you know, we have needed, if we don't have to have it and then switch at all.
OK, All right. Thank you.
She became a break.
And come back to that.
That little thing right there. This way a walkway around.
Again, I'll be going.
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It has got a flash drive, so we bought the person from scratch.
So just let me know how it looks like to try that.
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Amy, can you see right now?
Yes. I think we probably want to put it in French. Style. Certainly. Yes.
Go ahead and click your Escape button, each packet, Then, under Slideshare, see, slideshow?
Yeah. And criticality offer views, Is that if you use Batch data and then just hit from the beginning?
We're ready to change the traffic. Or even if you're not here.
Yeah, yeah. Yeah. Yeah.
Just. let me know, OK, Sounds good.
Thank you, sorry for the change. OK.
Oh, yeah. Also. Touched On it.
So, this is your policy.
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That's OK. Let's say. We should.
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Yeah, oh, sorry. I apologize.
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I Am here OK, Oh, welcome back, everybody.
OK, so you're ready for the next session?
We have two very amazing speakers.
And after that, after the presentation, we will have lunch.
So, we have doctor Kenneth E E.
From K E in our veins out. From the crowd.
Oh. Thank you. Thank you so much.
All right. Can everybody hear me OK, fine.
Good, Amy, you can hear me OK, OK.
Alrighty, so I like to introduce ourselves.
My name is Penny on the dollar, The associates honor you so far. She's the person, the owner of Brown Environmental. We've worked together quite a bit and on on many different projects.
So my qualifications, what I've done, two decades with Oklahoma State University, about two decades with American Airlines.
So I've had a good experience in us.
My research stress, Environmental Chemistry, all the emerging contaminants, specifically deep fast, hazardous waste management, industrial ecology, and environmental forensics, which is a really upcoming topics specifically for the past.
This is our lawyers system. This is our disclaimer.
Be honest with you, a little about ourselves. Sometimes we do presentations together and people get upset. And I don't people, You know, we're not, lawyers are not politicians scientists. These are to use our opinions.
Myself, I've studied Chemistry for the past five decades.
This P fast is the most complex chemical issue ever, ever studied.
It is that complex. My history, I went to University of South Florida, studied Chemistry on the East Coast.
I actually had two professors on the Manhattan Project, 19 43.
My introduction of the fast was in 19 70, and those away, before, most of you weren't even born, 27 years, after World War two, these professors were still talking about: Be fast, amazing, as a chemistry student, 27 years after the war. These individuals were still addressed effects.
And, um, quick history, talk about quickly 19 38? Font get Freshly minted PHD student. Moved to Paul was one task to General Motors.
He was told to develop gaseous, picture influence, the experiment failed terribly.
Accidentally, you know, the very first solid floor needed hydrocarbon.
This waxy Solid Gas for Liquidity was designed it was designed experiment to be a gas. it failed.
again, terribly, proved the most slippery inert material that existence. we call this today chatbot: All type or for 40 only. That was 19 38.
And it's interesting is a photograph of the sale to experiment. And this is one of the most interesting failed experiments, because people keep photographing.
They keep pretending. You know that they're doing at the present time, but here start performing on the right-hand side. This was folks in a gas and it's actually a white powder.
Dupont could not find anything to do with this material, it could not, it would not stick to anything, so they literally put it on a shelf, but yeah, this was supposed to be a gas.
Um, 93 more years later, and Oppenheimer, Oppenheimer in Manhattan Project both Germany and Japan and the United States everybody who's in the gaseous diffusion stage, Germany had a four year Head Start on us.
And one of the chemists at the Manhattan Project actually mentions, I guess to Oppenheimer, that one thing we can do to change, the whole idea is to differentiate or enrich YouTube 35 from from YouTube 38.
They coded the cylinder also they need a semi permeable membrane from chatbot and that is interest even after World War two. Historians look at Germany, Japan.
They had developed very, very little of the Enrich 235.
We obviously did all because of Pete best.
It just shows you one thing how from a chemistry perspective, how recalcitrant these molecules are very recalcitrant.
Then again they actually use this with valves fields gas fits, all coded. Don talked about this earlier P fast. It's an acronym per QALY, all it needs, or more than one floral contain fluorine out your It contains carbon.
It's a Rollup firm. We do not know how many compounds there are. We believe it's over 12,000.
It could be much, much more. This is how complex this is and they have all kinds of names. They also have these common names Chat on those things.
I always give me the fast, because like a tree was greater than 12,000 leaves.
P fast is the family, the big tree, each one of those leaves represent one compound in each one of those compounds within Bath is gonna have a different toxicity.
Different mobility, different cast, the different K O W different every day, It is just absolutely. This is why P fast is such a complex, complex issue.
But I also think it's pretty interesting is that chemists have taken certain of PFS names, abbreviate them to make them easy. Some of them may make sense.
The FOAS P FOA, it makes sense.
The other ones, obviously, what Public Relations firms, and I like this one here, for a blah, blah, blah, blah, blah, Donna, as long as I can walk a center, doesn't it?
This one here, X of floral probably oxide dimer acid. Nobody wants to say that over and over again. I love this, Gen X You can tell a public relations firm.
Ali ...: Thep: Longest stretch if we call gore tex: ...: Acid I love this one here, Scott, starting to everyone. Here, it's a mixture of the floral surfactants, .... We call this. A Triple F sounds like a professional wrestlers. So, these names, a lot of these, are, sort of made up by public relations, or, some of them are Canvas.
And it's interesting, with a very interesting article in the history of the planet Earth.
The fast may be the most expensive hazard in our history, in the history of the planet Earth.
This dawn to this is the cost is going to be unbelievable.
Adverse health effects, and all stay every day, every week.
You hear about all these kinds of problems at P fast, can create in the human body, and also cancer.
Here are just some of the cancers we believe are associated with the fast, one, the city has come to answer is, to stick it up cancer or firefighters.
And according to CDC and my osh firefighters have a 9% higher risk of the being diagnosed with cancer, 14% higher risk of dying from cancer than the general US population.
And one theory is that turnout year.
And we're told for years that this turnout gear, the same material we use gore tex, does not have absorbed through the skin.
And there are all kinds of studies now read that apparently there could be self absorption through sweat, and through the skin EPA has established, established this turnout years interesting, a lifetime internal health advisory level for the FOA, zero point zero zero four parts per trillion.
We can measure that out of the way.
Burnout here goes about 20 billion arts for trade.
It gives you a perspective on what the firefighters are exposed to on a daily basis, and there's all kinds of research articles on this.
So let's talk about the water. I never really thought that greatly waterside. We'll see how these are all related.
When we think about drinking water cycle, your stores, then we always have a discharge, you have a source discharge, and then you have treatment, treatment around the treating the water.
You introduce PFS into the source. It's going to go through the treatment with right now. There is nothing that remove it for some time and you're gonna get the faster, the discharge. However, that discharge may be somebody else's source water.
My major professor, doctor Bates from State University's always pop up the Mississippi River, so you overhear, hypothetical yesterday and that's the source Water up to Minnesota.
It discharges downstream, and now we have 100 parts per trillion effects, CDB.
Its source water is downstream of this.
Now, CDB discharge is now 200 parts per trillion. City, state, and see what's happening here. Then, CDC is charges at 300 and he goes on and on. And so, as you go further south and limits the river, you can literally file Magnify P fast.
So let's talk about the Clean Water Act.
two wonderful documents to read. What is F one guideline plan? 15 came out January 20.3.
This Boxes Memo came out in December 20, 0 to 20 22.
In summary, if you were to summarize both of those together, here it is, EPA wants the reduction of the fast and both. Static Jerry Sewer, Pre pretreatment.
Storms or NPCS.
Which will reduce P fast and surface waters in bio assaults bottom line is reduced in here. And here you're going to have less people asked in the surface waters and the bio solids.
The nice thing about it here is a wastewater treatment facility city they have P fashion, firefighting industry, commercial agriculture, landfills, then you have P fast now coming into the bio solids.
And into the treated water going, It's, what people, what US EPA wants, is essentially is the reduction of all of those sources, which does make sense.
Totally The PPS Guidance Memo was very interesting.
The goal, if you read it, is to reduce the fast from industrial your users are you use the industrial users, Therefore, EPA monitors the influence of water in the effluent water to be received industry and Biosolids. All three the end for the effluents and the bio solids.
There are so interesting, this came up to me in 19 94. Actions and walk to the white, is still on the Internet. How things have changed. A plain English guide to EPA are 503 Biosolids Rule. We see how all those benefits your cattle grazed it is, you know, agriculture, crops, roll your roses, whatever it is. They have this large document on all the benefits of bio solids.
Folks may imagine you have a dairy farm. It's been in your family for hundreds of years, and now you cannot sell them milk.
You cannot stop with milk due to the bio solids.
This was in 19 94 how things change.
Yeah, JFK, non rural.
In 19 62, State of the Union address, you see the phone is sort of common sense, but I thought it was pretty interesting.
You don't repair a roof when the tornadoes on the ground ready to hit your community, you don't repair the roof in the middle of a thunderstorm.
Its point is a time to repair the roof is what the sun is shining.
This is the time when you think about right now. Ethos is not a wrapper waste.
It's not a circle of waste, I mean, right now, this is the time to act. This is the time to act.
My advice is this time you start to live in a fast as now, to find the P source and address it by product substitution by product substitution.
four takeaways, I want four things I want you to remember. Level one, Conductor P Fast, Document Assessment of the Facility. You have facilities. Consultants should be doing or or EHS managers, number to conduct an ethos, chemical analysis facility.
If number two is positive, then conduct the forensic analysis of the PCAST analysis.
Number four, use the principles, industrial ecology to eliminate the P fast.
Let's go over these.
Now, I told you step number one, and now I'm going to tell you what step. What number one generally doesn't work, which is ironic to say the two major pitfalls.
And number one, try to eliminate any chemical product, will award floral power?
The major issue we see is the following: the bottom line under osha right now, 29 CFR 90 10, 1200, Appendix A If the material is a, it is not considered a known carcinogen, which is not.
Bottom line is: in the last it exceeds 1%. You don't need to put it on the SDS.
It has to exceed 1% for non carcinogens. Let's do a little math.
1% is 10000 parts per million.
10000 parts per million is 10 million parts per billion.
10 million parts per billion is 10 is 10 million parts per billion is 10 billion parts per trillion.
Therefore 1% equals 10 billion parts per trillion. Think about this.
I can put 10 billion parts per trillion in a product and I don't have to put it on the SGS.
This is the reason why when auditor I go to industries do we say well that the FCS is look great?
OK, in this, this is one of the issue. And again, does not reported on the SPS. You can see a big major loophole there.
And again, EPA's Health advisory for the FOA, 0, 0, 4, not even one, or for truly, look at the difference, this number five year, year, it's just unbelievable.
Now, sometimes, silly.
You get lucky.
You actually see the word floral.
Any time BCB greediest for all, you know, it is a P fast. Because fluorine does not normally bond with carb, and they're so rare, very, very rare exceptions. So most of these are our PDFs.
Now, what companies have done more in cosmetics, They use brand names.
And so, unless you're a chemist, you see hey, to, you don't know that.
These apps are paid, then, to actually this, business number two, or number three, and the list goes on and on there literally, hiding what they're angry ingredients by using grandniece. That's one reason why sometimes step number one does not.
Step number two, conduct the chemical analysis of the facility tray and use P by sampling guidelines, state.
You scientist, one thing we have to always remember if one day we want to maybe have this admitted in a court of law. it has to be admissible in court of law.
It was simple in Florida I will use Florida's Tamplin guidelines in Oklahoma.
We use them.
Our goal was simply guidelines.
And by the way, Lauren was one of the co-authors who actually authored the, the feedback, certainly guidelines for the state of Oklahoma, analyze, keep as people through sanitary and storm sewer not just use sanitary storm also. A storm water.
See what is the contact with rain water, and then the discharge.
Which peaks fast should I use analysis?
What is so interesting?
I get calls all the time, and people wanting to follow this US. EPA test 83 27 ASTM I'm telling you is one of the real problems if you read the consent orders.
When you read the judge's consent orders, what you'll notice is generally yeah.
Everyone, I have ever seen, the judge is, saying, You're, you are to use these protocols, and these, are my recommendations for drinking water use by 33 by 37.1 and obviously, this is only 25 ounces, £18.
Anything, other than drinking water, then we use tests. It's a draft 6 to 33.
It has 40 compacts, auditors addressed TO app the one real beauty of ...
the analyzer greater than £12,000 on time, and actually, you can do absolutely everything with this, but these are the protocols I would use.
The problem with some of these like ASTM protocols. they may not be admissible in the court of law.
Therefore, again, my recommendation is used one of these for a combination of these chemical analysis.
US EPA's B Now, when we start doing test methods, this graph, that's 16 very weak and TLS total 40 warriors, that two reasons, number one, test method 633 only analyzes, or you think, about 100%. It only analyzes for SQL on 3% of P fast or doesn't really know.
Fraction. Number two is all the tests that 16 33 don she addressed. This also does not just for precursors. It does not test for each element is very concerned now with the street cars.
So here's a little diagram.
This is the total of the fast graph method Test, 16, 33.
This story is this little sliver 0.33%. one of the real beauty of it measures, essentially, 100%, the difference of Delta is 99.67. Therefore, we generally would do a testnet 533 to 5, 37, or 633 in conjunction with QOF, and begin we'll be addressing TO GO.
Dawn also addressed surf up super fun.
This Federal Register came out April 13, 2023, just this year. And it's very interesting. Circle is eight.
When you read it, The Federal Register, they've already proposed to their proposed seven More Now, All we have nine compounds in. You. See the pattern, and Don talked about this. It's not going to start off with one. It's not going to stop to.
It's not just with nine, and it's very interesting. Here's the list of compounds Testament in 16 33.
The big data issue is these two, then I added these seven over here, at least seven, see what's going to happen next.
It's pretty obvious. They're going to go down this list.
EPA's have suggested they're going to also regulate the best precursors.
Precursor is the precursors chemical. that is transformed into another out through the course of a degradation process.
Why is US. EPA so concerned, precursors.
And I like this analogy.
Forget about PFS. Let's say he was actually want to do or why you're within your waste stream.
The active ingredient is ethanol and they're actually going to be testing for ethanol which is the active ingredient, why the analysis shows zero.
However, analysis also shows: we find grape juice.
We find yeast in water, your waste, any fermentation of grape juice and yeast and water equals Y.
We get calls from ... views, it does not make sense.
We analyze the influence of the water coming in, We have zero P fast.
Test method 633.
However, we're showing them the biosolids. They're high fast. How can that be? It's just the limitation of why you think about these precursors.
You have a cursor, tell them or alcohol. You have the yeast, you have a micro-organism, hot water, you add these three together, and you either get degradation or some kind of meditation.
I've always thought about these precursors, Troma, Trojan horse.
What do you think about ears, industry, industry to discharge? They need a stormwater permit, or they need a permit?
Here's industry and they're asking the city, or the city says, We need a permit.
They're saying here's our chemical analysis.
Says you can look at the list are ways to be fast three? It does not take effect. However, the precursors are the Trojan horse. And again, precautions, chemical that transforms one to the other.
There has been doesn't dozens and dozens of research articles, on all these portal, tell them or alcohols, bio degradation, and you can just this one article which you can see right here, ETF TOH. Here's a precursor of Tumblr All down here, the FOA.
You need just like why permutation? You need some water. You need a micro-organism.
You need that, essentially, the grape juice isn't it?
That is the precursor, step two. Step three, step two is positive.
For P P fast, then conduct a forensic analysis, environmental forensic analysis, to potentially determine the origin of the best outcomes for both the compounds detected in the relative concentrations to other compounds.
one good example we get involved is a Triple X This is firefighting. Foam matching every airport in the United States. Big and small, are all you can do with this.
Here, you have this phone is called a Danish since the atrium left.
And this is just a 62nd timelapse, I, I've been in 2 or 3 of these, then that 15 minutes.
And the scariest thing is 10 feet above your head and it's, it's like a terrible blizzard.
And by the way, this is not snow.
And the only thing you can do, to be honest with you, is you have to open the hangar Doors.
Um, you can't, again, you cannot see your hand in front of your face, is that, and they are very scary, shown to the right.
About six or on the right-hand side, Just watch.
And that's just, it's still coming down.
And when they say, data system, it is day luge is.
Chemical constituent a triplet have evolved over time from 19 60 to 2002. It was PFOS based on studies. Usually PFOS. Here's some other other constituents that this was the made in green.
Later on, from 19 70, 2016, you see this, eight to the PS two FPS. Look at the differences are all atra, but chemically there are different.
Let's go a little further, 20, tens, the president is the third generation resource, moderate and short chain, or telework a triple F 6 to 42, FPS. And the signature most predominantly like this.
Therefore, I know when you are looking at the ratio of the different molecules, we can determine not only what the material is, but when wasn't introduced to the ground groundwater or into the soil.
The other interesting thing is a triple F there are different micro-organisms in the groundwater. surface water then, wastewater water biosolids. We have a lot of people which are rewarded, urine and stuff like that. The micro-organisms here, when we get from here to here here is the original.
Each way notice how about changes due to the micro-organisms.
so different bio degradation paths depending on the vector slowing, which is, again, part of the events.
For instance, this is plastic manufacturing and this is probably the FOA. There are some other ones is the catch basin.
This is predominantly the landfills, CP, Picasa, landfills.
You have this characteristics of the fast compounds.
The other really interesting thing about forensics on the past, this is a hypothetical appears the Arkansas River.
This company that's hot discharging Hypothetically P, fast here, we check downstream and we see the same signature ear, your ear, and we know, and again, this is not absolute proof in the cage.
If this if this is the origin, it may indicate that these are all the same factory, you know. So, that's the other thing that we do.
And looking at how each molecule degrades over time, not for you, but it's sometimes very complex because if you go many different ways depending on the micro-organism that is exposed.
So forth or takeaways. Number four is use the principle of industrial ecology to eliminate the thief as chemical.
one of the most important underpinnings of industrial ecology. is Green Chemistry. Green, Chemistry here. The 12 principles of Green Chemistry. Look at number one, that, waste, number two, designs, safer chemicals and products on the three design chemicals and products that would be great at the use of ECP, fast do they do not.
And one of the things we hope to do is looking at the effluent.
If it is positive, then two work with the chemical vendors to find non E fast substitutes. non P fast substitutes.
It's interesting being older right now there's a lot of great car waxes that contain PFS yesteryear we use Criminal bollocks the old people don't remember Google X It worked very well today.
Everybody wants the, you know, the facts always yesteryear I mean in, in finding solutions, suppressed.
Before we used to do what is called Ping Pong Balls. Like plastic balls worked as a few suppressed and on point solution.
Today, everybody wants to P fast in the plane solution, as huge press of my four years.
We work with your specific vendors to find non the past, and it should assess.
When I, when I was I remember newly married went to harvest store to get barbecue gloves, all the barbecue gloves, power specimens.
Everything is festus everywhere.
They finally begun specimens, PCBs. All the lights, fluorescent. We don't have the ear but all fluorescent light ballasts are loaded with PCBs. Halogenated solvents are decreased.
A lot of companies, aerospace has gone back soap and water, soap and water to clean aircraft. Imagine that versus halogenated salts.
So let me do her presentation then. There's questions you can ask us.
So, good. Then, with that part up there, so I know that's not yours.
Oh, yeah, that one.
Just real quick, before I get started. I do want to give just a little bit of information about the environmental affairs.
We are a test laboratory survived the test laboratory services to those organic chlorine testing methods.
By combustion ion chromatography. We have two methods that are what we call, direct injection method First one: They are bringing the total working in a boring matches. And Tory also offer absorbable and extract more organic way, that those sample preparation methods, and we're going to talk about in a minute. So there are some pros and cons to using any of the sample preparation before you do your testing.
The next bullet down there, we are able to analyze Nibbles on-site. We have mobile laboratory services. We have this technology in a mobile lab.
Or alternately, shipments are locations are scattered off site.
If, if we're on slide the next bullet there, we can offer rapid analysis.
We can offer an 18 minute runtime in TLS or tunnel boring.
So, this is really helpful if you've got a project where you're cleaning out a process, or say testing your treatment systems, and you need to know whether or not the conditions are appropriate or correct, we can test it, We can be there on site testing for you, then provide you with those answers to shut down, wait for testing results and start the next one to the bottom: the Liquid to Solid Matrices. We can perform this on any any type of wastewater influenced, effluent biosolids, any chemical waste anymore.
So just a little bit about my background, really, really quick, so I am the President and owner of Brown Environmental. Before this, I had 10 years of regulatory compliance experience. eight of those were in the aerospace industry. I manage aerospace defense programs, including as 10 already talked about those areas of a triple F aqueous the forming of fading and metal finishing. And in addition to that, I do have 15 years laboratory experience, both academic and environmental testing, research labs.
Then just a little fun, although I've got it right here. It's been nearly 15 years ago. It's hard for me to imagine, but almost 15 years ago, I was doing my PHD work. And I was actually working a lot with the Oklahoma City and the animals here, and the Animal Keeper. So this is very fact. That this area is, in honor of this.
very special and unique thing, you, I've included many of ours slides.
The botanical garden swell, their collection of over 16,000 exhibits, attraction, over 1500 animals and 15,000. Are here to get a chance to see any of these. I highly recommend that you will enjoy it.
But in order for you to be able to see all of those, you see I've got a roadmap on the right here. So the Oklahoma City, they've created their own roadmap to direct you to collections of information that are available for each of these.
When you visit these exhibits, there's information there to learn more.
If we think about the faster, we switch and think about Their group, as doctor ... already mentioned, 12,000.
And just for fun, let's call them a group of exhibits that are similar.
But, unfortunately, for key fast, we have very little information about each of these individuals.
And even less is known about PFS and our domestic waste, our environmental resources, and even ourselves.
Where do we go?
Well, US EPA has provided their own PTS roadmap with major goals of restricting discharges of their source, katina, comprehensive information on these charges, including the concentrations, significant sources and types of compounds are being charged.
So when we're talking about PCAST, how big is complex?
Well, it depends on the definition of the database.
They can use a broad definition of a pen, you would find million.
Some of those are shown here in the green.
Now, it is generally recognized that there are currently potentially thousands of different key fast, and it turns out that if you look at EPA's lists, your dashboard for the past is now sitting at over 16, so that's where we're at. Right now, this number of cases continues to grow.
Then, as we go back and look at doctor E one keypads treatment over 12,000, please remember that each one of these leaves is a different type of ETFs.
And, of course, you remember from the previous slide, that we're now up to 16, over 16,000.
So each one of these people, please, the comments there will be all of them are different. type of the best. At each, the best. They can come in a different shape.
A different structure, different conformation.
They can come at every size from the smallest to the largest.
And they span across the spectrum of PFS functional variations.
But what do they all have in common?
Well, all keypads containing the carbon fluorine bond.
If you look in the figure, these are the blocks compounds, combine to the floor.
The all the key pass, no matter what confirmation, no matter what shape, no matter how they are oriented, they all have this carbon fluorine bond.
So a couple terms to remember.
Remember that organic chlorine and it worked out. Fluorine mean the same thing.
And that they both of these terms, mean that you have a compound that means that carbon fluorine bond.
So what can we do with this carbon fluorine bond?
We remember that all boring, but not all or get a flooring is currently considered PTS. We're going to talk about that some more in just a minute.
And that not all PFS can be measured. But all organic flooring can be measured using the carbon fluorine bond.
Then it's really that carbon fluorine bond. It becomes the key to measuring total.
What's the problem with this? Well, we run into what we call the PTS iceberg dilemma.
And so, this is really where we're capturing either less than 1% of the PFAS, potentially, in your sample, or we're capturing over 100% of them. Are ugly organic farming?
If we look at the tip of the iceberg that is, for example, using Target ethos method, they identify less than 1%. And an example that we've already spoken about a lot, is Draft Method 16, 36, 40.
We're looking at the entire iceberg. This is all the oriental for a measure. as we've already shown the measure of the carbon fluorine bond is currently the best of the method for total.
The problem here, the caveat is that it also detect some compounds that are not currently considered PDF. There's still organic fluorine compounds currently. They don't fall within that PBS definition, which I have to say the definition is still being defined the plot.
So, knowing that, what are not the examples will currently things like fluoridated pesticide, a lot of those are not considered co-ordinated Pharmaceuticals.
They also fall outside of this group, and also some other things that we would traditionally consider PFS that might have other ... groups attached to them also. Those are right now.
However, they are still synthetic pollutants and they are still detectable by organic chlorine.
It's a requirement to disclose.
That's fine on the right shows prior knowledge of a process of a waste or the waste stream can really be helpful, right? And especially in this case.
And so, industrial discharges or sources of fast. They also have a duty to be aware of pollutant levels in their effluent discharges and then be able to disclose that information to a point.
There's lots of potential sources but ends up at the ... which we are calling the receivers of course.
Now, the problem as doctor has already talked about is that many industrial sources may not know if they have PFS discharges, because those safety data sheets may not list PTAC gradients in.
concentration is less than 1%, or, I've seen this, especially with a triple F, if they're considered confidential, proprietary, or a trade. So they can actually add more than 1% and not listed on the yes.
And so without testing, scaping the unknown and undetected into our environment from the East undeclared.
Alright, so what's the plan to deal with it as well.
EPA's LG TV MP, Both April and December 2022 Memos, They require TO TW studies of influence affluenza, biosolids and industrial sources.
They require testing using EPA Chapter three as Draft Method 621, which is the verbal or inquiry method, and they add the caveat, if appropriate.
We're going to collect samples, and we're going to test we need to have some sample collection: do's and don'ts. Right.
Now, I know later on today, we're going to hear a little bit more about the don'ts: don't list is extremely large. It's an enormous list, In fact, if we look at Oklahoma, he has given us a whole list here of protocols for sampling.
If we look at the table of contents from that, let me see that, that don't actually make it 10 or 27 pages, that's many, many, we don't.
I know very well.
Adults, those maybe don't. Do you need to follow those, they are very important.
However, what I want to talk about today, is a few of the do's, OK?
Do collect comparable samples.
So, you want to strive for equal amounts of liquids and solids between your samples.
Sludge they're gonna be a challenge for comparable samples and we're going to talk about that.
PFS, what we see, especially in the total working on exploring testing, we've seen that a lot of your tasks associated with the solids. So they don't all released the liquid fraction. So a lot of them say your biosolids. It's attached to your bio solids.
So, if your solid content varies between the samples, so will your best values.
So, if you're wanting to look and see how fast it's changed, over, time, make sure that those samples are shareable.
one other thing, the alternate samples will result in loss of feedback.
So another do collect the data appropriately sized containers that will be sent directly to your lab.
Can you guys talk about they can be sticky, like the peanut butter in this jar over here, and they will be lost if you're transferring them between.
So a few more of the do's. And I think we touched on it just a little bit. But be aware that some of your key tasks are actually volatile.
So you want to collect your samples with little to no headspace as as directed by your receiving laboratory. So, depending on how are you going to handle your sample is a way to phrase it. may be a small amount of sample had stays otherwise to reduce the amount of bone loss trial. Like she said, well, with little to No.
Do know that sample pretreatment sets of filtering extraction adsorption will receive the best losses from your sample. Now, for many of the test avoidable because you'll have to do the steps that for some of them for other tasks, you do not have to do stuff so you can see more of the total.
Then, finally, probably the biggest do that I can recommend here today, is, Do make sure that you're getting every piece of the pie, and what do I mean by that? Well, if we use this as an example, so what we see here are four different industrial wastewater effluence.
The blue is what we've measured with target defense methods. And the rest is the orange Here is everything else that we saw with soil organic boring.
And you can see in every case, the majority of the organic compounds are not detectable using the targets.
OK, so let's talk a little bit more about our total organic chlorine.
Remember that total ordinary methods to detect all the carbon fluorine bond of all. So, if you look at the brain circle here, you can see that all the blue circle is all of that is captured by now. The top circle is a little bit larger than the past and still capture those. Other four are. not forever.
Here's a dash G circle. Those are.
And they do capture a significant portion of the PCAST, but for reasons that we're going to talk about this next slide to you to lose some of your people.
Then, finally, dropped magic, 16, 33, little dots in the very center.
It does detect 40 different types. And, those types of identifiable using you can detect the aoa. You cannot identify this individually for that 63.
So, let's talk about either perforate, the subtract method, 16 21.
So, if there's a time when it's appropriate, there has to be a time when it's inappropriate, right?
So, when is it inappropriate?
Well, it's inappropriate for everything, other than aqueous, non volatile pages.
It's inappropriate for your sledges your clients, all chemicals of your version or use carbon present what other removable media sites for your volatile Pete, that 16 21 is not.
Of course, when is it appropriate, well, as we just that, it's appropriate for a non volatile matrices only.
It can be used for inorganic fluoride from your standpoint satisfied.
It also is used to reach lower detection levels that search and that is used to capture and concentrate PFAS compounds so that you can get down to the low parts per billion. And that is higher than the parts per trillion that we look at for our individual compounds. But we're looking for all organic.
This is an incomplete capture in search status. They captured results in the loss of their incomplete or competitive binding. So you can see here the middle.
We have our sample pretreatment that, as a sandbox, we have to run through two carbon Poland's theories in order to capture more of the ALS.
But what you'll see is that there's a fraction of the ..., and a fraction that is not.
And if you look at the graph on the far right, you can actually see a perfect laboratory condition. We have ultra pure water fight to keep a single site. You can see how much actually breaks through of that first column. And this is really what's measured. These are only what was detected in each individual policies. When you add things like other sample major environmental conditions other additional carbon, other contaminants even higher.
And, of course, here, volatile P bats are often loss, and filtering steps may be needed.
The steps before you run into those absorption: this particles may be needed, which is going to add your key.
What can we do? Well, it can you just go back and look at total organic 40 methods to use the same instrumentation and analysis.
The direct and indirect object, your samples there no sample preparation steps, and therefore we don't have the key facets. That we can do this for any combustible material.
Inputs, affluence, any chemicals, any treatment media, we can convert those.
And like I said, gnocchi fast losses to sample concentration or filtering uses the same instrument.
And currently it is the best available tests, are total capacity measurement. We can do it rapidly in 18 minutes, for total brain. And it is the lowest cost.
And so with that, I'm going to say thank you. And I think open it up for questions, if we have time for the panel.
We all meet for a minute.
Any questions, call? We have a couple online KMS. I don't know if you want to start out with those or start with the ones in the room.
OK, guys, is there any question in general?
Should be listed on ... No. Heat Loss Plus regulatory action.
I think that would be an ocean question. Oh, **** related decision, that is a known carcinogen.
I think it will be able to answer that better than I can and is patient, but right now, osha, it's not clear.
And the other thing is an auditor brought this up over and over again. This trade secrets, we see this all the time.
Trade secret tracing it. Yeah.
Question and Yana, one.
Amy, Yes, cranked here, the first one is, are there are P fast free alternatives to a triple X that insurance companies have approved for aviation use.
I will, I will take a shot at that question, because that's that growth and advances every day, but it is my understanding at this point, we do not have either an FAA or Department of Food, for a brief brief, but now, one little caveat about the floor to although they are labeled as 43, they are still allowed to have up to one part per billion Vitiated PSAP, and in fact, they can have more than that of total organic for a still waste product, although there's a lot less PFS in them. There still is going to be small amounts. So, if you're doing a testing, and also small amounts may read, my may remain if your infrastructure in your delivery systems, if those are not switched out. So just keep that in mind if you do testing after you switch to the story. But at this point, I do not know of any that have been approved. I know that they're making advances that I don't think that any of the standards yet.
Into your hydra. Next question: are there examples of car wax that contain fast? We typically receive water from car washes.
Very good question.
And my answer is, I I have tested the F one I should say, we have tested the effluent of car washes, which I think about there a passive acceptor.
They don't generate the P fast themselves.
And, so, we have found, yes, some we have found, no, my own opinion, the older the car, wash facility, the higher the probability you're going to get the facts, told you it is, the generally. higher probability, yeah. Yeah.
Thank you. Doctor Reed, one more question.
See, 16 33 encrypts a small number of PFAS compounds. How about total mass to the 40 compounds? include most of the ... mass present in most sample?
Is a triple app. We do do a lot with firefighting foam. The answer is no, A lot of it's very heavy in ... alcohols.
And that's the reason why, and, by the way, I always talk about this.
When you do 16, 33 parts per trillion, parts per trillion.
When you do TLS, many times we see parts per million parts per billion.
Always tell students this, sort of close your eyes and think about your last annual salary.
What did you make last year and try adding six zeros to whatever the difference is zeros to anything. I don't care, what is it? Nor bad parts per trillion billion. Yeah And sometimes people will do analysis, these numbers seem so high, is a real estate.
On 16 33, orally measuring 0.33%, not even 1%.
That's the real beauty.
And, by the way, that's the reason why I don't change is here Why US EPA is going to be starting to do this because these telemark alcohols certainly do file degrade to PF P at PFOA and PFOS.
Any other questions?
There's one Oh, oh, sorry To create your slideshow with your willingness to share.
From an US EPA regulatory standpoint, it's a question.
This is the first time that MCL is under the publication process for a long time.
Ads, we noticed that one of the things driving such low standards is that the laboratories or detections, as you know, most NGLs, aren't based on Minister Science based on what laboratories are able to achieve at the time those MCOs Spec.
The question is, this is step one of opening up an even bigger and orange box using MCOs for others digits.
That's an excellent question, because what I've seen lately in Chemistry is we have been so focused on the facts.
If you talk to candidates right now, what is the latest technology and exiting? The chromium? We've been using the state, makes it into Chromium procedure, You know, the last five years, 10 years? And years, 10 years?
So we have been so concentrated on these groups of compounds.
The lack of a better term we have ignored technology on other compounds that other the other molecules.
More toxic than benzene is a good example.
David sparks benzene analysis for this lifestyle. Change. run. The analysis.
Yeah, Before. Yeah. Decades ago, we're still use the same technology. Yeah.
Good question. Yeah.
But if somebody were so focused on P fast is, this is the problem child right now, with the lack of a better, have ignored the other MCOs.
Do you see that changing?
I know I have a hunch.
I have a hunch that fast right now, student the complexity, and the other thing that I foresee, yes, I made this prediction for a long time.
The bird pitch that we use in Afghanistan, they put a triple F in those, and you do not burn a triple burn it.
A lot of the unfortunately, our soldiers got exposed to atomized a triple A lot of these telework alcohol's, then they Inhale.
And I think you're going to see change in the future, um, at least partially on campus.
Like every NaN, I have a hunch you've been here. You've been exposed to a burn.
call our law firm.
Because I think that some of these are ways I don't seek peace that's going away anytime soon.
A good example we know benzene, known carcinogen.
And I'm quite old.
I can't remember the last time the analysis of benzene, the has changed, because we've been so focused on other compounds, I just don't see it right now. Yep.
Deserve the hard questions.
I see scenario is taking place.
So, I know that the specific it asks.
So, it's limited in the number doctor ...
methods now densely look for the signature of more than one standard methods.
The clients ask you, Hey, take a sample of this.
and that's comparative results.
Then we daddy's really easy to resolve.
This is in that space, but then, doctor Soper, it's gonna give me an hour or so.
Then let's take the scenario, where should you name it, that, Hey, I see something. Now, assault.
Saudi, is it safe to send it, for like, what do I do?
Both of what we do on a situation, I guess, good example is in Green Chemistry, try to find the source.
What is causing that TF two left to be high? Now, if you are passively sector, like a landfill or a carwash, there's not much you can do right now.
However, in industry, plating solutions are prime example. There are other few Suppressants we can use right now. There's a lot of Green Chemistry, we use chemical substitution.
OK, well, and the only thing that I would add to that is that there are some things, The differences, there are differences between the types of tests, and so the adsense say in this vitiated tests, and the presence in all doesn't necessarily mean that we have a problem here. Just as we've said, there's so many other compounds that you could see with the top, with the total organic. So, it actually really good kind of quality control check for your sample to tell you whether or not you do still have potentially some fast for a risk in that sample before you would send it to wastewater. So I think by adding talk to your analysis, that gives you more confidence in a better assessment of the risk before you with discharge.
Doctor Mitchell's, an online poll. Question for you to put your thoughts on a couple of additional tools, top assay or non targeted PFS analysis, you see those as being useful ways to kind of fill in the gap of the unknown between TANF and the 633 analysis.
I'm sorry, Mitch, could you repeat that? I couldn't quite hear you.
What are your thoughts about top assay or an untargeted ... analysis, as always? Please.
To bridge the gap between organic fluorine and 633 LLCs.
Got it, got it. So, I've got your question now, OK. So, you are asking about adding the top asset, which is the total oxidizer, both precursor assay or using, I believe, non targeted other non targeted methods to fill the gap between the total that we see with top versus the speciation. And what I want to say about this for for right now is that, yes, you do have some more options that are being developed that top acetate, essentially. What happens when you do that is that you take your sample and you expose it to oxidizing condition. You break it down so you break down the pathos and their effect on any of the precursors. But in order to know how many were precursors, you have to do at 633 abroad in the beginning.
You have to visiting your prep step and another 633, so these get very, very expensive, and you're still missing some of your talk, you're still potentially missing. The organic pouring in your sample, so it's really a combination of methods but I think is the best approach and you just have to determine for your individual project needs, which ones you want to go ahead and pursue. You can get total information using the organic chlorine method. And if 633 doesn't give you enough information about the species, yes, you can add top assay, and there are only a few places where you can get the high, the non target, The additional non targeted analysis.
But, if you want to add those, you can, but once again, those are also going to be the most expensive category right now, OK, does that answer your question that?
Yes, very good, thank you, OK, thank you.
OK, any other questions, I guess, if we do, we can, cause I think it's lunchtime, so we can save all questions, too, and the speakers on site.
Alright, we come back.
Director and General manager for me, which includes all three Oklahoma location.
Danny is the primary instructor for on-site training of accurate QA, QC development program that he's training, Public Water Systems, and Industry swallowable Retreat, you equal player means they chose played a crucial role in accurate lab space you see him.
That's an indication of PFAS in 2004 and was also the principal investigator for EPA, SB Phase one grant award, grants awarded in 20 18, but P plus one, so. Sorry.
Kids should be right next. And then just make sure.
OK, well, good afternoon.
I am the technical director or Acura Environmental.
Today we're going to talk about You see them are, I know we've talked about it, some of the earlier presentation.
And my goodness with our spouse.
So I'm going to just say, some of the highlights, I'm going to talk about sampling, but I will, I'll talk about these EMR.
Why we're doing it, some of the results that we've already got, from the past analysis, from ECE, Kamar three, and then what we're doing raised five, and then we'll talk about 633, just in general.
I'm sure some of you will have pushed.
So, the ECM R C M R, stands for unregulated contaminant monitor, or, So, every five years, EPA will select 30 compounds, 30 contaminant, should say, that are not currently regulated and drink the water So, they're looking at the candidate list, seeing what they'd like to regulate, or saying, what may be in the water, what they'd like to test for.
It seems a little may seem a little trivial. Why are we going for all these things? We don't even know if it's in the water, or maybe it is, maybe it isn't. But especially for P fast, huge survey, I mean, it is, it's, you know, everybody, all water systems. At least for use EMR, 5, 3300, population, at 30, 300 and above. are all doing a few of the smaller ones.
But it's a huge survey of what's out there, what type of concentrations were looking at. How many, how many samples were positive and per watt. So, we'll talk about that here in a second, but it's, it's a, it's a tremendous project.
Again, all sorts of serving more than 10000 are fired to participate. now, they're gonna pay for that.
Themselves, from 3300 to 10000, I believe the APA is paying for that, some of the smaller systems, and then under 3300, that is just to be selected.
Is specifically for drinking water.
So, this isn't no wastewater, no stall is is just specifically or drinking water and even more specific is generally finished water Especially for use EMR five is all finished water. There was an ...
three, there was some, some raw water and mash resident sites for certain things, But for the past analysis itself, is finished water.
And the ..., which is several years ago, again, each one of these are five year segments, so you say I want 3, 2013, the 2015 was the actual sampling period, or key fast method was 137, the original method reporting limits between 10 and 90 parts per trillion. So, when we're talking about some of the stuff, the part per trillion, that we're looking at today, especially, are proposed MCL, even lower than the lowest. that we looked at back in 2015 or so.
Use EMR five, a little bit different. We've talked about this it was mentioned earlier.
There's plenty nine TFS server. They're only picking 30, 29 of us P fast and only though the odd one lab slip.
So, two different methods, 5, 37.1, or by method of 5 37, only for Comcast for that. And 533, there's 25.
So, reporting levels are all well below, 10 parts per million, parts per trillion, trillion with a T, And so, and we can reliably see, somebody asked me how low can you normally see for the ..., just a good, low answer, is what I mean. It's something, maybe, lower than that, sometimes, maybe a little bit above, but, on average, right, around one is what what equation capable of seeing?
There are specific sampling requirements for the .... It is an EPA program.
Very specific, they give out requirements for laboratories, for sampling and uploading data, and so on.
So, they're very specific QC requirements, solve all of that is included in the Program.
one of those is field reagent so we're going to talk about sampling. We will talk about Bill reagent bikes.
What they are, we talking about method blanks quite a bit and that's, you know, just clean water that you're taking through the entire process. But for a field reagent blank, that is where we're wanting to make sure that any results that you get your sample are actually from the sample itself, not for contamination from, you know, the clothing. You're wearing our hand sanitizer or something?
So we will give, be fast spring water out, and this is all verified.
Why a lot. So we'll make a batch of what we call the fast Free Water send it out to the field, and then you're pouring that up along with the actual field samples to check for contamination of the environment. Something you're wearing.
Who knows where it might come from, but we're displaying to verify so sampling kits that are sent out.
Lab will provide all that. Not, Don't.
Don't use your own models even even if we're talking just about 633 and some field samples or whatever. I mean, we get people to try and bring in all sorts of containers.
You know, don't bring in your your Aquafina Model or or doctor Pepper, a mason jar or something like that.
I can't confirm that, that was clean when you started. You're paying for this analysis. Do you want to make sure that the results you're getting.
So, uh, so sampling, a 45, 30,000, 250 mil polypropylene, there's some preservative That's all added beforehand. You worry about that.
Out of the thing I wanted to point out is the temperature temperature for these, for these EMR, we have to receive it at 10 degrees C or less within the first 48 hours.
Doesn't sound like it's that difficult, but a lot of times, we're shipping and all over the country.
Could be difficult. The people are generally not an issue, But if you're shipping it overnight from New York or something like that, it may be an issue. Now. It's not technically, we have to receive it, and 40 hours, we have to have a way to document was less than 10 degrees C and that 48 hours. And that is a lot harder than how it sounds. So, it sounds like that would be easy, but it's nearly impossible.
As long as we get a first 48 hours defined, and then we store it, six curiosity, or less for 14 days. So, this is actually one of the short our holiday times, is 14 days. We'll see some of these.
Other samples will go, like, 4 or 5 33 goes to 28, um, hundred 33.
Again, you are picking up polypropylene arrays to be a little bit of a preservative and same temperature requirements, But, again, 28 days. So, it makes it a little bit a little bit easier.
Then lithium the odd one here, 200.7, 5.
Now plastic with nitric acid, this one has no specific temperature fire, but you're sending along with your other samples, so just distinctly.
So, contamination. We're hearing about that this morning, it can be caused by a million dollars a day, so, Doctor ... and some of the students like Lauren has put together some guidelines on the DEQ website.
There's a link from our website at the Sampling Instructions page, There's, they even list out specific brands, that are, you know, that are verified to be OK, and so, I would take a look at those before you start to do any sampling. Just make sure you're, You're not contaminate thing. This is one ear, the aluminum foil there I believe, maybe even in the 16 33 method.
It talks about fish that you can wrap those in aluminum foil and send them and I would not I would not do.
We've, we've I thought that was a little suspect than we did some testing, with just an aluminum foil that we have a laboratory and we did fine even for four hours. Or. So, I would stay away from aluminum foil but, what is, say, a much smaller list, unfortunately. But, H P or polypropylene is stainless. steel is always fine.
But, thank goodness, I said is for my two, Saviors are ziplock bags and nitrile gloves. I do not know what we would do if we did not have those two.
So at least you can glove up, you can take your your containers and put them in the box and it should be fine. Wash your hands thoroughly.
Be careful the soap you're using, obviously, but you know, wash your hands thoroughly, get them in the nitrile gloves with your supervisor.
I, we actually did, we had, what's TV and Michigan. They've, they've got a wolverine landfill that had a bunch of contamination, and they did they call, it did a segment, just about sampling and they were kind of under the impression.
It's very difficult and homeowners do it, and so, it is really not that If you read the instructions, and all very basic guidelines, it's, it, it's not that bad stuff.
Um, feel great, like, collection.
So, Collecting the blank. At sampling points. We're going to take the water, you're going to transfer it to your, to your container, We're going to talk to the top. We talked about that earlier.
Now, this is your field blank, So you're going to treat it just like a sample from this point forward, with a couple of exceptions. You do want to put it in its own Ziploc bag. So, they'll store it with your samples. You may have a high concentration sample that you're not aware of, so start a separate zip top bag and make sure it's labeled properly.
Uh, oh, And yes, there's import order of operation, right?
You want to do your field likes before you do any samples. Again, you don't want to contaminate anything. And so, if you're collecting your sample, you get your sample on your hands, or your gloves, then you don't want to go through into your mailbox to do all your field blank for both methods.
Get those secured in a cooler.
And then go ahead and do your, your sample collection itself.
That separates ziplock bags and not just for, for paypass analysis, but this is a good good idea for, for pretty much all analysis is that you need to be ice down. All right.
And so, blue eyes are the little ice packs and so on. They don't, they don't completely encompass the sample ball. So, it usually, it's just a small section that it's in contact with the sample bottle, they just don't cool really well. So, we want to use what? It's actually eyes, right?
But, you don't know the quality of that, as they follow.
You don't know if there's if there's P fast then, that or, the cooler that you're using, we've received coolers before, for bacteria analysis that they're just bobbing around in an ice chest or water.
Granted, the inside should be fine, but at some point, you have to open that lid.
And, if there's anything in those threads, you're going to emanate your sample just as a general sampling guideline would not for all of your samples without them being in a Ziploc bag or something.
Um, field sample collection, so you've got to sample the field sample exactly the same way and make sure you keep it in the same cooler as the Field gradient blank because our life and ammunition we're looking at is through the trip back to laboratory.
Again, talking about 4 to 8 hours auction, and they must be half or below, 6, 10 degrees at arrival, and then we'll store them six.
Now, what all this work, and all of these water systems that are doing the sample collection, sending in all the analysis done and not to mention the data upload, which is not straightforward, lets you bugs.
Anybody that's uploaded data. I'm sure shocks. It doesn't go extremely smoothly but there's hiccups here and there.
But in the end, the end product is what we're looking for, is a data summary. Again, a huge, huge survey. I'm not sure how we see this.
But these are the ..., three survey that were, I'm extremely interested to see these EMR five, because of the number, and the reporting limits are so much lower. But for the ECM R three, the only two at that time that had some sort of health advisory or something was, PFOS, the FOA. And you see the formula that we have here for PFOS was actually 40 parts per trillion, so pretty high, relatively.
And the health advisory levels that we had at that time.
Number of results that we had was 37,000.
So it's quite a good number of samples that are collected, and then the ones that were above the reporting limit at that time which isn't a huge amount. It's, it's, you know, it's about a 30%, not a huge number.
But there's about 300 that had results now that again the elevated reporting so we'll see how you CMDR five comes out. It's going to be interesting.
That's kind of the ... process, how, how they're selected.
You know, what compounds which ones are doing now, sampling, reagent, blanks. And then finally, the final product is the data itself. Now we had talked about, earlier are exactly who mentioned that.
It was actually on this I cut it out to try to make the The The They had a little bit larger, but we actually did. An excellent problem for you. See them, are great.
And there's A similar number of results, actually, I think, is about.
But the reporting levels, 30 latest micrograms per liter and zero point zero three micrograms per liter, very low reporting level.
And it was more there was more water systems that had results for ... I believe it was about 75%.
It was It was huge, huge number, but today.
we're not talking about Hex Bella Chrome or dioxins or PCBs work.
We're talking about the thing that everybody's addressed currently.
Which is, so, again, we'll, we'll see how everything plays out, But, now, 16, 33, we've talked about this a few times this morning.
Then it, except for drinking water.
Doctor you'd mentioned this earlier, except for drinking water ETA's Recommendation 633 and they also have the 621, um, the it is, it works very well for aqueous samples, biosolids soils, works very well. We actually haven't done any tissue samples.
We do some some fish tissue samples bud's for pesticides or mercury or something we just haven't had a quest for.
But, um, so, previously and all the ..., all the test methods have been for drinking water.
But, because, the stuff in Maine with biosolids and so on, it's everybody's kinda forced to make up their own their own math.
So, but, instead it now has a draft, but we'll talk about some of the changes and some of the complaints about it and so, on, uh, yeah.
So, it's appropriate, again, for aqueous Style sallows biosolids.
It does do 40 PFAS compounds and it's done by isotope dilution and so it's not the normal straightforward. We do a calibration, and you're comparing response versus what's on the calibration and stripe that bullish. It is, it is a little bit different for the isotope dilution. So what we're doing is we're taking isotope labeled PFAS compounds. We're adding it to the sample before doing the extraction, not before analysis like a normal internal standard method, you'd add those after extraction, but before analysis. But as you're adding it before the extraction. And so any loss and recoveries that you're getting, in that extraction, you're assuming that those actual PFAS compounds you're looking for, had the same loss. So you're normalizing those results.
You're calculating those results based on the loss that you had, an extraction, so it's supposed to be a much more accurate math, and we've seen drastic changes, some of the concentrations at versus previous central standard.
Um, EPA does have SWA 468327, but it's not an isotope dilution method, especially for, uh, wastewater solid isotope dilution.
I think it is the way that all of us for P fast, you know, at least CMS wise, it's going to go.
The wave, we've noticed with, the more difficult ... we don't get good recovery, is when you do an internal standards, It's not making up for that. And so, even dissolves sallows, even when it looks like you're getting OK.
Recovery's, but then you're running on the instrument, and there's all solids are causing problems. I mean, all of that is taken care of, or at least help pollution.
And, like everybody said earlier, 16, 33 is what they're recommending for things other than drinking water.
We have had some landfills that are acquiring biosolids before they're supposed to be tested for. PFAS now, are PFAS compounds.
The request method 16 33, some of the there is a little discrepancy with the list that they're acquiring this different than the 633, but they've accepted decision 33 method that analyte list.
So, if there's any confusion there, they've, they've, they've, it's been good about accepting the actual list from the method.
There's been some critiques of the draft method, especially the first revision that came out. There's been several vision, I believe, are on the third revision now.
They're expecting a fourth, and then a final eventually, but, um, you know, they've had some critiques and enough to EPA's credit, They have went back and got some of those, put out some revisions, not just validation, but sample collection, and storage one of those was typically for aqueous samples for all the drinking water. It's 250 ML sample, but here they are talking about 500 mils.
It's argued that it's not needed.
Or at least confusion. We can see down to similar, it's really only going to have big, when you're talking about 1 or 2 parts per trillion and a half, it's not a huge difference. And a lot of these matrices it makes a little bit more difficult because you're getting twice as much dissolved solids on there twice as much interferences. And so, 250 ... works works just fine.
And also as I believe, as doctor Ligand Stauffer mentioned earlier, that some of these are sticky as well and so transferring all I have volume for one container and you may be leaving behind a good amount of those are still not a representative sample.
Original draft required family frozen upon receipt at the laboratory. This was a big one for us.
That is going to be a problem. We've got dozens and dozens of refrigerators. I do not have dozens and dozens of free. And so, and none of the previous methods had mentioned freezing samples. But this one had talked about that, and so it's now been changed to where it's 28 year old, as long as you're keeping them less. So that was definitely helpful. Poor performance.
It's poor coverage, particularly internal standards, which could see, you know, because we're using those internal standards to calculate aspiration, but that could affect things.
They did come out of the second draft, a lot of general corrections, and just elaborations, as well as the first draft. So, they went back and revise some of the equipment or part numbers. There are some typos discrepancies.
There is a interesting with methanol, and water, is required to be in the extract itself.
So, for some water, or for some soil, excuse me, need to determine the water content just to try and Matrix match on the instrument.
And extract dilution were explained in more detail.
We've had conversations about dilution and solve our clients, they're done a little bit differently on a 16 33 Sam storage again was chained up to 28 days.
Lesson six, biosolids lasts six up to 90 days, which is nice, it does recommend Frozen do-do odors, Um, we work in the environmental field thought, or they were pretty used to odors I'd say.
But, um, but, I think we're fine. We can, we can all deal with that. Third draft edition, so this is December of 2022. The legs on, I want to say it's just the other day, but as we're six months away from that now, they did include multi laboratory validation. So, for us, I know it doesn't sound exciting, We were very excited to see this, because what it does include now is the acceptance limits for wastewater.
So, which is very helpful before we're doing control charts and generate our own acceptance finance, and we weren't sure exactly where we stood on the bus recovery in the world, and I know I'm not sure, is that what everybody else is getting? And now, we feel much better that we have acceptance criteria.
We can see and compare ourselves to do what Mall type Validation has, or so, and then also single laboratory validation for solid tissue.
So, and I would imagine, in the next revision, they'll have the multi laboratory for solid tissue.
I don't think they're going to change any procedural. You know, anything having to do with the chemistry of the method itself, I think, goes to be more validation, maybe a few revisions. But, I think it'll all be minor stuff.
And how well does the method work, and what everybody wants to know?
We've done several samples by 633 wastewater a method works for the clay methods and there we are. We're thrilled to have played out methods. As I said previously, we've done extraction or just general abstractions and put it on the instrument. There's no no real cleanup for the methods that we had kind of made together.
So, dissolved solids or other organic interferences are are does really well say about the biosolids, the soils, it doesn't really well cleanup, it's a completely different procedure for water and soil.
The soil you're essentially extracting it and making it almost an aqueous sample. And then you're going through and doing the extraction on the aqueous portion. So, it works, works very well. But other liquids right, we have gotten quite a few samples that are not, what I would call aqueous and definitely not a solid.
It it works.
OK, but I do not think this is a map of this year. I think it's just a very difficult nature.
So, we've had some that are, Sophie, we've had some that are, you know, petroleum contamination.
I mean, there's, there's all sorts of samples that people just want. I've got, somebody told me, I gotta check this, I'm standing there. Can you run it?
And, there's been a couple times, We can't do that. There isn't theirs.
What's your brain to me is, I don't have a minute or so, but, in general, so, aqueous samples with petroleum contamination or something like that can be done and the cleanup does help quite a bit. So But I was, this is where it's not really what the method.
OK, and tissue, I said, before, we haven't actually done an efficient issue. We do quite a bit for the client, but we haven't done any smells yet.
So, for sampling, we talked about 500 mils 250 miles is fine. We don't want to, you know, sub sample. So, 255, much better.
Less than six degrees C, All the times 28 days.
And, again, for special, for special projects, normally we only keep samples for 30 days, but for special projects, we can freeze the samples and all the time, still good, up to 90 days.
Very helpful when you have space and a freezer for a Few.
It's, uh, it's, it's pretty straightforward method. It works very well. It's nice to not have preservation.
We're talking about how these are fairly stable and the environment then, and so on and wants to give them a bridge. You know, we really need preservation.
I have Shannon drinking water, but it's very nice to have a method where you're just collecting the sample soils biosolids. Just HTTP Compare.
Again, same temperature, less than 50 degrees C Once we get it.
Then, tissue samples. Same thing.
You can, you can ship whole fish with due process fish.
We can cut them up and do whatever part that you would like. Some people like to include the liver, some people like to do just the edible portion are going to be consuming and so on. So, either way is fine.
Within 24 hours of getting up and I believe this is the one that mentions the aluminum foil. But I would hesitate to do that. I would use. So I found out and they make huge bags recently.
I had no idea, but they they make huge So your your your official All the time finding days, again, will restore the frozen laboratory, but I think this is just re-iterate what we talked about.
I think that's probably it.
If so, what do you notice when your temples go over the old because they're just a lot? That's supposedly yeah.
They're going to change like we've talked about, you know, doctor E and like, our software talks about precursors. And so, they're going to change. Now, it may be a target compound, and this is where it becomes a problem for us. It may not be so much for TLS.
But for us, the problem is that if it comes in as a target compound, but then it's it's changing to something else, we're not going to, business. It's no longer a target for us to work. We're only looking at those 40 for this. It's mostly chemical changes the way absorbed drive because we do go back. We'll rents the walls of the container. Yeah, and that's another thing that we want to use the entire volume.
We go back with solvent and and check it out or water it and make sure that we get that extract.
So yeah, absolutely can, very good question.
Any others? Yes, sir, question.
Then someone brings in a group, of the same samples, 30 samples thrown water in the field reagent like, it's not like, Yeah, that's, yeah, that's, that's a good question.
two answers to that.
one is, for you see them are kids, We, we, we, everybody.
Yeah, what, you cannot subtract.
I guess this question all the time, you cannot subtract the line in the actual status, correct? Absolutely, no blank, subtraction, nothing like that, and police EMR, they want even accept the data that's positive and the field reagent why They don't want that, they don't even want to know that it exists. So we'll, we'll jump that. Send new containers, probably talk to the client about sampling procedures. on, they'll re sample until now, for the 16 33, at this point, that there is no field reagent, like art in the math. If a client request one, we can absolutely send it, but it's data were reported as is. So we'll send you the data, will send you to feel reagent blank data.
So you can kinda kinda like a turbine for, you know, for volatiles, we'll send you that.
And then you can decide what the key here also save your client lot of money is half the points on the first that's true in the wind.
Spending another $50,000 on data that is not admissible in court, you wasted all that time waiting for all this has got to take more time to process it.
Yeah, I completely agree. Yeah, for the SMR, we actually process all of the samples first.
See if there's any result if nobody has any results, we didn't even do the reagent once because it's not necessary. But for 16 33 and so on it, most likely you're sampling for a reason.
There's probably going to be something there, so yeah.
So, next update.
Yes, some are bright lines, yeah.
The unity with the active session, because you can exceed that bright line.
Now, you have not alive versus shot, so, yeah, what? I said, good luck with that factors.
Now, let me get the results.
Yeah, it's It's for, well, for, for drinking water is what you're asked. Yeah.
So, specifically for drinking water, most What is nice?
We're looking at MCL, maybe for something like that. I don't want the proposing. And my thought before, we can generally see down to around one from us. So, that gives us a little bit of a buffer. I I hate to just be able to see down to the MCL, because you really don't get it. You don't get a good picture of what you're looking at. If if the MCL is for your reporting limit is four, and you get a 3.9? Are you going to four point? one?
on this does not apply if, You know, And a lot of time, And they're the exact same result based. So being able to report a little bit lower, And then we would report that number. Hopefully, you know, if you wanted to make the, report, that number and then kind of, like for you know, for 11, copper is similar or not.
Reporting right down to the MCL works and then, you know, DEQ, or whoever the regulatory agencies can can make decisions based on it and make it a little bit more informed decisions for that. So that's, that's what we're hoping. That's what we're looking for. We do for the drinking water method.
And I believe, the 633, we, are running a, a spike. We're running a known, at the reporting limit itself. And so as far as, you know, how how lot of methods were just running something at, the Calibration apparently, high concentration, but, for for, these are actually running something at reporting limit. And we've gotta get within a certain recovered, so that that helps with the accuracy based, Just to make sure you're saying thanks.
Anything else? Yes, I have two questions. Automatic or manual extraction?
Yeah, we have Agilent asked me this model. Really? Yes. Yes. I can, I can find it for you, Specifically. Pinterest, I can't imagine anybody else being interested in that. Well, maybe I know specifically for, you know, a 60, or 40, I believe, is our old one. I think, the new one.
I can't remember what That, assuming you're using different methods, actually, they can, they're both validated for, for both methods. We typically know, kinda keep drinking water on fire and the others on the other, But they're both validated of past the all the criteria. So if something was to happen we could we could go back for the extracts aren't. Mister ... does not like petroleum samples where there's a huge difference between one another the carryover and contaminations.
We increase the methanol to 100%, flush everything out. It's pretty much so. Yeah, yeah.
I will find the truth, OK. Let's save all questions. Thank you, sir. I study.
OK, so, our next speaker, we'll be covering Changing Landscape of Phase one, Our main sites estimates and close them.
So, we have missed that then, Right. All right, so nice.
Um, ever a dull Engineering and Design Manager for Quick Trip Club in Tulsa, OK, Quick Treat, owns and operates one thousand convenience stores and field station across 16 State.
It's rapid expansion after us the country.
All right, thank you. Can I just now entering Oklahoma City, of super excited about that coal from Oklahoma City originally for Yukon. So, spend a lot of time to do and I'm just super excited.
Not going to work for a really big company that has now a presence here and authenticity in my backyard here.
You might be thinking, why is a guy from a nice organization talking about key bots?
Yeah, we, as I mentioned in the, in the bio, we now own and operate a thousand different TV stores as of two weeks.
So, in any given year, we're building at a rate of about 60 to 70 stores per year, which means that we're buying properties.
Somewhere that array of I'll give you an example of last year, we we performed around to learn it.
Phase one: environmental site assessments, on properties that we're looking at purchase, so we're really in the business of looking at properties and understanding what our risk and liability is, an environmental viewpoint.
You know, I've seen everything from Christine Rebuilds, that we look at all the way to the being at the doorstep of a Superfund site.
Thank God, we have not bought anything within a Superfund footprint.
Yes, need to be changing things, which is one of the reasons that I'm really dialed into this issues, have done the work with doctor Ian Audran Laurent here in doing some really early investigations to understand what our liability.
All right, so, with that, let's get started. Here, the topics I'm going to cover for those folks that aren't familiar with what a baseline environmental sites that are, just what environmental due diligence is, I'm going to give a quick primer on what that is just to contact them.
Then I'm going to dive into a little bit deeper for the folks that do live in the, in the due diligence world. What is the difference between the new ASTM standards? And that is that as the protocol is embedded into the certainly regulations of how we go about performing what's known as all appropriate inquiry on it on a property.
OK, then, the 2021 Stater, introduce this term of emerging in order to define what that is, then we're going to move into the theme of the day, P fast, and how that, how do we deal with that today?
And looking forward, how are we going to deal with it, more risk management, and so on.
We're looking at performing a baseline environmental science.
one of the key elements is performing assignment, OK? So a qualified environmental professionals would go out and do a sidewalk.
If you stumble upon a site that looks like this, it goes without saying, that problem, right, OK? Those are easy. Those are easy, wants to the same point.
We've got issues. Now might not be so easy to untangle this rottenness of environmental issues.
But, let's flip it on the other side of, walking around, You see Business proceed.
Oh, you know what happened out there?
Not abuse, OK?
So, the flip side, maybe just as complicated, trying to figure out what our sample, so that is a key indicator baselines.
We never perform, you see.
So we're doing everything by desktop.
She interviews, sidewalk.
These are professional judgement, OK?
So why do we perform based one?
So you're gonna get a different answer based on who you talk to.
So I'm gonna give you a minute let me use the best answer, sir.
As afforded three different liability protections embedded into the regulations, if you perform what's known as an all appropriately re baseline, Those defenses are simply another event because he was property owner.
Quite restricted first, dive into all, that means the legal ease.
But what that means is, if I perform a Phase one or the standard, I will be afforded huge liability protections under strict law, even if I buy a property that's contaminated.
The sign-up bonus by prospective purchasers, defense.
So, let's say if that is tied up in a legal battle.
If there's finger pointing with previous land owners, operators, maybe even discussions with regulators, If I can say, Look, I perform phase one, environmental sciences, ownership is property.
I said, Effectively establish the baseline, right?
Oh, when I took ownership versus who, Whatever activities, Pardon me, OK, so this is super, super important to me.
They get those defenses, particularly in the case of he talks in all of a certainty that this revolving around, right, with all those, not just liabilities, court cases that are that are coming out, we're going to be happening next 10, 15 years. I want to be able to secure that fish.
But more from a practical standpoint, Phase one, and Phase two, if we do.
Borrowing due diligence has been a really good lesson, great information about just how much animation is there.
What do you understand on the cost of cleanup and how the performance or the ROI that buying a property you already use case?
And, then, lots of other risks related issues that we really want to better understand whether it's human health, environmental safety, environmental liens or activity activity, Huge limitations of property can be used.
We really want to just understand what is the context of risk? If we purchase this property, OK?
Now, another answer, you may get somebody, when you ask why for phase one of the banks, time, you do it in order to get a loan to buy property, that's very, very true, OK? So, you perform the phase one over, and in some cases, they didn't do their own baseline in conjunction with your face, right?
And that could very much influence whether the date says this, or this on it, on their movie, OK? Same thing happens for insurance companies.
Whether they decide to ensure the entity is going to be fine and operating that property.
So I've referenced ASTM test the American Society of Testing Materials they perform what's known as the the standard.
Now Federal Standard of how it performs all the appropriate inquiries on through seven different revisions, the first version, and 93, the most recent in 21.
We'll talk more about what those changes were If we won this is all codifying the circling, OK?
So at the at the heart of the ASU baseline, we're trying to identify the presence or absence of a rat OK, not a train right like what you saw in the first few photos, but we're talking about the recognized OK, and that is a very clear definition of substances under surplus.
Certainly, hazardous substances, which there's about 800 of those, they're listed under ..., and then this way, petroleum products.
There is not a defined list of petroleum products, and if you look within the statute, that's really referring to Clean Water Act, but what petroleum product isn't, any substance that causes the Xi Y J.
So why do they include something that's very definitive without a list of this?
Quite a bit more nebulous. Well, petroleum products are everywhere.
Drilling product contamination is everywhere.
And at the time, when they were developing standards, it was considered the most widespread elimination.
We could probably replace that now.
So, all in all, again, this is the environmental professionals in we don't have a sample analytical evidence to prove the presence or the absence of the content.
So, think of it almost like a private investigator, It's putting these clues together to determine, I think there's something there, the likely presence of environmental condition is there.
We need to maybe, take another step, understanding what that receives, OK, so, here are the elements of your standard page 1, 1, 3, 4, can be done in really any order. This is sequential, OK?
So, I'll take you through what, What normally takes anywhere from 20 to 40 hours quorum of bays one, about two minutes, OK?
We're doing the wreckage review, looking at, looking at topo, maps, soils, maps, geology, hydrogeologist, Flood plains.
What you're trying to do is understand for this property, what does my, what does my box look like, the soils and water and what have you? So you're looking at it.
The information like what you see here are different maps.
You're also looking at databases, state and federal databases and those databases are going to our information capture is surplus, Superfund sites, Rick Regenerator. ... is landfills.
Underground storage space there, so there is a very prescribed list within the baseline of what you have to look out to.
It also basically, how far out do I have to look for my subjects?
OK, historical property, use research, so you're looking at historical aerial photographs, historical, sanborn, APPLETREE, Fire Insurance Match.
So think of the days prior to Google, the new alert, what they find you have to use in order to understand what was there?
How I, how do I need to respond?
You see it.
These days, they've that literally like the 18 fifties in some cases, OK, really helpful information.
As you can see here, this is a map that not only gives you what you can see here like above ground storage tanks, but also describing what the property title or to the name is, that was there.
And lots of great information that you can look back in history and how has that property used?
Then we're going to do our sidewalk or cyber constants, or we have to basically on the ground. We're going to look around looking for those signs of emanation.
The new standard very clearly sells out how to look for certain indicators for underground storage. And a very prescriptive list of things that you're on the lookout for.
Interviews, you're going to be interviewing past and current owners and operators or Lynn ... or ... and the local government officials, that's either face-to-face by the phone, produce, the middle of the foil letter, asking, has there been a spill or release here.
Has there been open remediation based.
Then you're gonna roll that up into your phase one report.
OK, so that Essence is what Phase one Now let's talk a little bit about comparison of what the 13th standard nowadays Theater 21, why we're talking about this, because we live in what I call those data.
February, the EPA basically said we have a year to operate within the confines of either one of these 13 or 21 statements, OK?
So we really need to understand once the 13 goes away, and that's next February, what do we need to do with our 21 Seats?
All right, Big picture.
What was the committee to?
Benefit from the fact that somebody on that which are environmental team participated on the committee. So really understanding what the heartbeat, Tim, what these changes are, big picture, there were no gigantic monumental changes.
What you want, really was certification of terminology, really, with the same time trying to improve the quality and consistency of making environmental judgement calls, OK?
So what you see here, quickly move through, OK?
Not gonna read everything on the slide here.
This really is for those, the, practice, the phase one to give you just a quick summary of what what that means like clarification to a reg, know, a cleanup or provide a little bit structure around you. Know, these Nebulas terms, like, likely, like the precedence is, the terminology is used for.
But this concept, I want to touch on because it was a hot topic that was talked about with me, was at that.
when looking at the thousands and thousands of different based on reports that prepares of those phase. one ports there was a MIS use of this turn it off, site, right.
There's no such thing within the exclusion of an offsite read or recognized environmental condition can only apply to the subject property that you're looking at within the business.
OK, So, let's play out a scenario, if you could be looking at a piece of property next door, there was it, cooling station, and had a leaking underground storage tank.
OK, only in the case that you have any good, the bad, the migration of that contain it onto the property, or there isn't any threat of that migration, will see the entry onto the subject property that label as a threat.
You can define within the report, hey, you really look like, but it really is just the cleaning up of terminology. So, why do we use this term Recognized environment.
The fall 2 points 2013 introduced: caveats or subsets of Rex.
What's known as it controlled, Recognize Environmental Condition at the store, recognized environmental conditions.
The only changes to the 21 standard really is, again, just cleaning up some terminology and further defining IT.
Underlying satisfy what that means.
Within the context is, the profession needs to provide documentation, evidence, data to support the satisfaction.
The site has been, the risk has been control of the contamination present.
Whether it's through a in engineering control, that control has to be still apply.
Work to make it white cap displace over a contaminated site that's used as an engineering control, well, that cap needs to be in place, that needs to be working, yeah.
Or that in order to be considered controlled, OK?
If it's not defined in consideration, is, that bump up to a red, All right.
For historical, recognize environmental conditions, really the same kind of concept is what we just talked about. There needs to be data.
It just works that can support the definite when defining the historical record soper.
For those that don't operate in the world of face once the difference between ear, the historical record is erect where we've gotten no further action, the concentration is below the lowest risk based standard in that state.
OK, controlled is where you could have closure too, but it's above the most, the lowest strip districts typically are residential senior for soil and water.
So you're living in a world of control wreck when it's above your resident residential risk based danger.
OK, all in all, if I had to boil down to the 2021 standard that they big ones, I'd say emerging contend to P boss in this slide.
It really is the the folks that are performing page ones with, click with, clean up, how we define these terms by getting a process flow diagram.
Also getting true 12 of the most practical real-world examples.
Where do you see a contaminated site? You kind of go through these common scenarios.
It goes through the logic of how you determine Brett Cedric age right Or, no, no condition at all.
OK, so, if you, if you practice in the world, the phase ones, I highly recommend going to the appendices in the Caribbean.
Because what that's going to do is really standardize how you make those judgement calls. OK?
I'm going to real quickly through these so that we can get to R P Boss this option, just some further cleanup of when to use, when we're talking about the property itself. Call it subject property on quality. Anything else?
Deduce the new 21 standard created a ship a shelf life.
let's say one year away from 2013, standard eight, we have you done phase one.
You put a date on the report in one year that baseline stonewalling, OK? but what the 21 standard did is for these five things.
air use, cleanup, please record searches.
You're basically putting a date on each one of those sections and once that date split on the report that starts at 180 day clock, OK so you could have 5 different 180 day clocks that you're you're you're tracking what that means within 180 days to go back into the co-ordinator, revision slip back to the user, hits allow purposes.
Once you would see that 180 days would be 180, 365, you can make revisions or it's not.
The 21 standard also, is standardized.
What's, what we call, the big four sources for historical sources, that space bullets here are, photographs, historical city directories, Historical Hobos, and you're seeing formats, You can.
So let's get into, let's get into the topic here.
Really, the biggest, probably the most impactful change, the ASTM Standard is that it created as concepts now that we have a lookout for emerging.
So now we're introducing our friend there down at the bottom or ...
compound, but what we do right now. What do we do right now and where we live in the world.
Where EPA back, and in fact, last year, may have 20 to 22, they actually come out with a proposal where they were going to give consultants, the ability to use either 13 standard or the 21. saint.
Well that created a ton of confusion.
OK, so there's a lot of public comments and what they did is they retracted that timber.
They came back out and said, OK, we're going to sunset the 13th standard and now everybody's going to live under the 20 months.
OK, so Happy Valentine's Day next year. Yay!
We now have one standard. Thank you.
To clarify things is really going to make things up so much easier. But for today, in the world, we live in today.
Just be thoughtful in terms. If you want, as a consultant.
If you have eight indicators, if there's people's contamination there or if you're the requester or the phase one, the 13th standard doesn't, it's not going to address those.
You could call it what's known as a business environmental risk, but I highly recommend it if that's something that you're dialed into as the user or the performer, that you want people to be a part of the due diligence, use the 21 standard, OK.
So, if you go out and you Google what is an emerging content scouring the EPA website, you're not gonna find? Any dot? I didn't find a Dot B, where it says, in a glossary, here's a term.
Here's the definition, but what you will find, what you will find are some fact sheets and documents, the EPA's publish.
And I've, I've purposely put all of these up here because if you are a consultant that's performing based ones, it's not just keep offsets in the state of an emerging content, OK. What else is EC cedar?
Emerging contaminants, well there's there's a listless scour, the EPA website, OK? Now if we look at what ASDS, as in two different sections, Is very nebulous like a lot of your ASU cedar language. So an emerging contaminant is not identified today as a hazardous substance under circle, OK?
It's not regulated by EPA or the courts, OK?
But what they do is they specifically call out one compound R P, ..., umbrella compounds that need to be looked for within the context of emerging contaminants.
OK, so today.
Consultant: debarment Professionally, Sincere.
When including emerging contaminants in their assessment, what's known as the ASTM Standard as a non scope OK, so think of it in terms of assess this.
Radon, mole, wetlands receives that don't fall into the circle, hazardous substance category of petroleum products.
That theme said, me as a quick trick that wanted to know about these property, that you might want to know what's out there, that would fall under a non soap.
And within the ASQ context, that's what's known as a B or Business environmental risks OK, fun, at which time these compounds are regulated, no, looking in the crystal ball.
strategic roadmap stated that people wanted to be designated as a regulated substance, there's some summer tweet three, OK?
If you're, if you can't track along the progress of the strategic roadmap, EPA is lagging about six months in terms of how they're holding up to their terms of their time.
OK, generally, I'm not sure if they're gonna hit six Multimedia through the winter, maybe early spring, next year, or Pete, Pete, Pete Boston people are considered regulated substances under served a little bit.
That's the way to attract, and now you're projecting a trend line.
That's about the timeline, OK.
Now, that's all, that's all considering. It's not getting tied up in litigation, which we can all expect that's going to happen.
That's totally different.
That's totally different thing. All right.
So, as I said, I'm not shaded.
It's in September 22, already.
She mentioned this on e-bay come out with a proposal to designate Ebola as hazardous substance under surplus.
Then April, you back out with this advanced notice of proposed rulemaking, adding those additional seven substances.
I would, like, had a conversation with doctor Eat about this.
I have real concerns about the way that language in that proposed rule states, because it's, you know, there was a great discussion about precursors.
I gave this notion that it was not just capture precursors. I think there are incentives to really try and grab them all.
How you do that, I don't know. I don't, I don't think you're going to get a list of 12,000 different things and circle, but there's going to be something to try and grab them all, and that's what my concerns.
So, today, this was a non analytical survey.
We used approximately about 12 different solvents to understand, OK, are they looking at people today?
All right, so really, it's which standard? or you use about half of them.
Right now, we're using the 13 Standard versus.
We're getting ready to draw a bright line, at least for us, and say, OK, starting next month, we're going to the 21 saint, OK.
As each month clicks along, what you'll probably find it as an industry is that we'll get closer and closer to 100% until our Valentine's Day deadline.
So, where are we finding?
Where are consultants finding peace boss, potential liabilities? A meet what business? Or what type of property used?
Well, we've got properties here, OK?
But within the elements of the baseline, it's sharing, government record searches, the interview process, it's a agency file reviews. Are there some findings that are that are starting to float out there, P box, in the documentation, or just through conversations, and interviews, and what chemicals and compounds to be used at that facility over time?
OK, I'll talk more about this subject in just a minute.
If you are, you're in the mindset that I want to know on the bus.
There are databases out there that are put together by states. There are some private databases. I think the environmental working Group has got a their own database.
That has started compiling data into like GIS formats where you can look at certain spots, certain properties and understand, OK, what does happen here?
Has there been a sample here?
Has there been some sort of regulated activity here that all under the abstract ...?
OK, I want to give a very strong word of caution about using, some of some of the databases are really depends on the state, depends on the entity it is put together.
OK, but there are some states, and I'll give an example of New York, where the data that is put into that database.
I consider poor quality, because the data, and that is not the only database, but some of the data was just basically based on the surveys that submitted to the regulated community.
Asking questions about, have you ever used ABC, Have you use key boss, you know? And so, with that sort of qualitative data, I'm not saying it's not useful.
I'm just saying, be really careful about using that to make a business decision and press, OK?
There's a federal EPA database, what's known as the ... tools I took a snapshot of Oklahoma see here.
It's really easy to use, just plugin, a bug in an address, and then what you find, are these dots showing where there has been, may not necessarily mean that there's action there. It just means that maybe there's a sample there, Maybe it's regulated, I'm sure, under a search program where people has been considered, so what, data, federal database searches, you can see here, whether it's a Safe Drinking Water Act database, it pops a database.
Clean Water Act. Brick red orange is the emergency response notification system, so typically that's going to be, you know, if you have like a triple that release, or something like that, TORI.
That's all embedded into this. Really nicely, you hover over it. You click on it, it gives you.
Know, the information right there, originally, usually, though, little bit more.
So it's a pretty good data captured. in there. That's sampled.
OK, if we're performing a Phase one study, I highly recommend understanding what industries are what I'm calling to the cross-hairs. OK, so you can look no further than the EPA's Aug.
Notice a pre-publication knows certainly knows where they call these 21 different potential entities.
And if you fall on this list, as a business, you see the current soar, it doesn't necessarily mean it is A Par issued back, there's been .... Which means that's in the processors.
You need to be on the lookout and there is a possibility that there that P plus is being used within, you know, that the business practices, whether it's storing it, making it, using it within these different business uses, OK.
I know we spend some time talking about ...
and how with the 1%, uh, maybe they're not quite as useful as what they should be in it, and I totally agree with that. But, at least, it is a piece of paper that, as a baseline investigator hadn't looked at that, and it might provide some of the science, like, what doctor even talking about, you see any new statutes that have to happen, loro or per fluoro on their portrayed names.
The ones that we're very familiar with, dry, with, Tip line, Scotchgard, some of the fun names that you might not know, at some point in time, that have, that have, had people ask me today, have been reformulated.
And that's another word, caution I did, I need to throw out there, is that, I know, from, from personal practice, not from operating each doors.
But looking at car washes, which is a venture that we're starting to get into and looking at and talking to manufacturers of chemical compounds.
It can be really difficult to try and get important relation from these quotes.
Did you ask about it?
What it boils down to is we just have your own standpoint.
OK, but what you do find in the answer to the question that doctor Reed answered about what do I do about car washes in the past?
The older clinicals there are very, it's very widely known that folder chemical uses that word car washes like you're on!
Uranium Sankey, whether it's ...
agent, doesn't have the Boston in here but what you will find with the major industry, all manufacturers and they're really only two in the country.
They have basically based off those clinical compounds, and we know now, I feel it, now says, Suits.
Basically, when Proposition 65, an hour for you, came down 2010 ish timeframe for the boss.
The Carwash chemical manufacturer started getting in line, at least in terms of what's used, immersion.
What's on the shelf at Wal-Mart?
Is a totally different Stuckey.
I can confirm nor deny, Latifah analytical.
But I can tell you that we've done sustainably we're scratching our heads out while we sample that chemical.
We've sampled in the affluent, the chemicals, but we're finding we're finding trace amounts here.
Where's that coming from?
We have some speculation about where, whether it could be like eight.
Coding on the, on the vehicle, itself, which is known shortly to have P Boston it.
or it could be a lapse or something of that nature that eaten by all are still at us P possible.
So, when there are indicators of a P cos liability, the consultant should start going down the road at asking, OK, if there's any kind of notion that it's been used, they're still there.
OK, we really want to know When where and how were those chemicals used so that we can start formulating, OK, do we need to start the thought process of sampling or phase two?
OK, the last few slides, Where are we going?
I think I hate this term: uncertainty balance really justifies too.
Every day today, whether it's from a, a legal standpoint, all the way to a regulatory standpoint. This is so quickly changing.
We need to just get a really clear understanding of who's performing the Phase one and who's asking for it that you get on the same page, as far as, what do we do about it, Are we going to even look at, OK, then you'd be surprised there's a how large, uh, when I'm talking about industry peers, a large number of folks that say it's not regulated, I'm not looking for right now. I want.
I don't want to open up that in the response, OK, Now when it becomes a regulated substance and you bought something that now could be determined as a circle of liability, well, then there's a problem, Right?
So, really understanding what the, the risk appetite of the user you, clearly defining the scope of Work. Super important. Knowing what the regulatory facts off with within the state is.
Another really important factor, especially if you're looking at properties and May, you're looking, you know, in Michigan, North Carolina Places, where there has been lots of case law and litigation work.
You know, a really strong regulatory program ramp up.
You really need to understand what that backdrop looks like.
OK, and that might help paint a picture, whether you're looking for Keep on ... with properties.
Obviously, if there's been either a known or suspected, use P boss, the release of peak awesome property, that's going to dictate whether you should make that decision is whether we want to dive into it.
I think this is another important category of the existing and delisted Superfund sites.
I think that to a radar that's low hanging fruit.
They are EPA's already read the process of sampling, sampling, PEAT Boston, the Superfund sites, were they just the search around, and look forward, to understand, OK, along with my ...
crane contamination, is RP bossier two?
OK, and so Open re-opening Superfund sites.
I think is going to be a real thing, OK?
The Biden Administration has made us a very strong push on environmental justice, whether it's just, you know, kinda the thrust of their strategic EPA altogether, but it's also embedded within the strategic roadmap.
So, what EPA has done, spend a lot of resources, and I would say that the databases that they have, the product they put out, is a good one, as far as mapping out, environmental justice securities now, that's still an ever changing.
It's still treating to be updated, but if I were a consultant, I would, I would want to know.
If there's an environmental justice here, because that's going to be in the cross-hairs, especially once the surplus designation comes down, Looking at those series first, OK, bye bye bye property in that area.
I just want to know that that's going to provide just another nugget of information to help you make a decision.
It goes without saying if we work within our world of environmental management, need to track the rules.
But I would say never have I, maybe besides like the US, have I've seen just the onslaught of articles and journals and things that I have tracked to understand what's going on, federal level, state level, OK.
So that's a huge thrust.
And as I mentioned previously, the roadmap they're lagging about six months behind at a state level not just looking at the rhetorics: looking at legislation that's going through their Congress and understanding.
What's what sort of things are being passed?
Unanimously example where they've actually pass a disclosure requirement of a seller to a buyer if there's P box contamination of water.
OK, and then we have this situation where we have all of this this hodgepodge patchwork of State regulatory standards.
She mentioned it, but it just creates such a complexity of how we need to navigate within one State versus another State.
And now, you look at this from the standpoint of the federal HCL that's been published four Parts per Trillion. Now all the States are going to have to go back, because they're really getting ahead of the game.
They're going to have to go back G dollar standard OK, So that is yet another thing that has changed.
All right, last name, Things to consider.
Should consider putting together what I'm talking to the systematic process, whether it's a checklist to, to really go down through it.
Proved to me the act of the requester of Phase one, that you've done your homework as far as, have you looked at what businesses search the database.
If you look at the chemical inventory, OK, so put together a system as appropriate today. All right.
When performing the phase one, are there any red flags that pop out, OK, so maybe it's not scoped out early that we're going to be looking at those liabilities but you're doing your sidewalk that you identify. In this case, like a class to fire suppression system.
That building's been around for 20 or 30 years.
The odds are pretty high that you're going to have Pete Bostonians system. Now, what are we, OK with it.
And so, you get on the phone, you start having conversations with whoever is asking for the Base model.
We are so Nuanced that further expanded what we're looking at here.
OK, let's say let's let's change the rabbit.
What what EPA only designates the Bosses Pete Boa, the substances.
Just think about how complex this is going to get.
For the 1998 bus compound, is going to be a mess, OK. How do we handle that?
I don't know how we get that.
This concept here is something it's a point. It can be talked about, not just the context of pathos. It can be tough.
But I think it's super important that not only the consultant, but the asker of the Phase one understands, OK, well, we put into that report, our findings.
If it goes to a court of law, you need to be asking yourself, does it preserve our all appropriate name for it?
So let's play out a scenario where there's no smoking gun. There's no red flag, but there are some tell-tale signs.
Childhood, a gray area, maybe the rest of us here, OK, how you structure the language.
What do you look for, how do you look for it?
How are you going to manage that risk, And he is super dicey what you are doing when you enshrine that HE report.
Then someday later to 10 years later, they punch a hole in the ground, they fine.
The mother lode keep us there.
That got me until you get older. It's gray language around, put them in there, who knows? Well, it just creates a real firestorm of what ifs.
All right, finally, I didn't mention it earlier when we're talking about just the elements and points of a phase one, but there's this concept of limits, the minimus meeting.
It's such a low risk concentration?
We can we look past it and not even recognize. Now, that goes away. That concept goes away, The key costs.
It's ubiquitous, it's widespread. It's an array. It's an art, was. It's everywhere.
So I think of them in this concept, and at least in terms of the boss, It's it's not good.
OK, so with that, That is the end of my presentation.
Does anybody have any questions?
Saving questions, OK. All right. All right, thank you.
OK, well, I owe a massive desktop here. There's lack of staff in exchange Stacks.
We should take a break, and I start my presentation after the break would not make sense.
All right, OK, let's get some blank, Can come back 10 minutes, right, OK.
Oh, yeah. Yeah.
Lauren, can you hear me?
Hey, any room? It's Amy, I couldn't hear you OK. There you go. Hey, everybody.
So our next speaker is a special one, Andrew, Andrew.
And I have worked together to put all these together without any and give them a round of applause amazing butlers, and have people walk with them on this.
So, yeah, is board certified regulatory toxicology since all stuff?
He specializes in developing and maintaining these strategies to assist me and I should also keep NATO regulation impacting industry, including rulemaking, SVT, call contaminants of emerging funds, such as the first, outside what pain points to a reading site, What's an ... machinery?
You so much, and enjoy the power that we have, which are special.
I'd also like to extend as being one of the committee chair for the technical content.
Thank you so much, all the presenters, for being here, Delivery Column fat, the Targeted Workshops, and also like to extend a big thank you if it's serious time commitment for y'all to be here, and those folks online as well.
So, thank you so much for coming in, listening in bosley questions, And hopefully, the time is now's path.
And I believe there was some advice, Yes, the slides will be provided. And I believe this is being recorded, in case you missed part of it and you want to look at it. So, again, thank you. Next.
I'm gonna step away from the audience.
I think I like payments modeled out, engage with the audience.
So unfortunately, folks online, seeing that the content is actually there on that on a screen for you.
So, you can look at that.
So, I'm going to change things up tremendous.
Actually, you know, very few information about the rules and regulations.
Some of the challenges are kind of strange station.
Practical aspects, then, let us, let me mention downwards looking at the very complex, legal issues.
So, let's talk about that, Laurel.
I don't think that there are those who truly understand holistically. It's just us.
two, I'm going to give you a small snippet from experimental results, specifically, why some of the regulations are technetium and even more specifically, what is the scientific basis behind some of these notes?
There's some interesting findings because beyond the sound laws we already mentioned.
The impacts are buyer or you can go on.
I think are you going to stay in the regulations and maybe compliance regulation?
It's worthwhile to understand the basics.
Me, all the regulatory understanding you provide.
Also, also broadening the natural, as you are eating, drinking, touching every day, I think it's always worthwhile to understand what is my personal risk so I can help people understand.
If you do see the files you have brought us, should I be personally concerned or my kids?
I can help you see if I can ask.
And, by the way, I'll try to take us back to be back on the schedule, working or not. Flip process. People online. Here, you lose your step away from the mic. I think I asked Amy and Amy, that you can text Loring about it.
OK, so, here's the rotor this. This is what, exactly I will stop here. In terms of the object.
So I'll move on.
Key message from this slide, There's a lot of information.
But the one message for you to remember: now speak slowly, dubai's, are not new.
Doctor, you mentioned that this goes way back.
Sending your spouse.
Again, remember, even though we are merging record for your phone service, the paths are not It's happening environment for all.
And I call these different stages.
Awareness: The first stage, what's the inception and proliferation.
That was a long period up to 2000 Johnson's nothing really.
Now, then, during this Stage two, starting about 2000 with voluntary phase outs of the long chain, T fast ....
It's through 2021, Browser Stage two. And so, folks refer to this as the Poverty Action Lab.
That's this second.
So, think about it.
There's a long pause, and now suddenly, the past two decades we have, now sends out the activities.
Then there's Stage three.
This is what we're in right now.
As you can see, based on the back ends for the slides, just looking at the line items, you can see slight difference And the State Street is now the roadmap, and the way I call it the multimedia regulatory actions, then times where you're not to read every single bullet.
You're just the grass.
How extensive the regulatory activities and actions are there. This is just federal government. This is not state.
This is not globally, this is just EPA.
So there isn't a single aspect.
Anything that the bandwidth is sort of a nice, new touch, the ... is not included.
And some of the things I highlighted because these are the water, what are issues.
Another quick snapshot is where are we now in terms of state regulations for all anytime.
It's just essentially rules, guidelines, anything that would state match.
And you can see the coverage, if you were to produce this map just a couple years ago, the number of those blue shades will be significant load stuff is coming up.
There's specific reasons why some of the states do not engage in activities.
They are precluded.
They don't have the resources most commonly, or, they, like Oklahoma, I think, are on TQ director, indicated that?
Just let us see what the gods that's not too, uh, pose any ashes that might be premature.
So, I think that's a conservative approach.
So, here's where we going a little bit into the realm of what are the risk based standards right now?
So, these are the water concentration limits, and you've seen the tables for PFAS compounds.
But the idea here is to have a limit, right line.
We'll talk about a whole mixture of hazard index, thousand folks who approach next, That below, which it's A Essentially, there's a ....
It's just safety And the number below that threshold.
And then by analogy, if we do exceed that pipeline then some type of compliance or actions to be taken.
That's fine won't talk about the various concepts and toxicology, chancel dose response.
Again, as they relate to regulations. We'll talk about that.
Then because a lot of our data are based on either laboratory animals or some type of non human, oh, biological systems are even in picture, didn't have to have some type of safety practice.
This a lot of sort of hits built into those numbers.
And then lastly and I'll talk about it, it's also very important that we need to select the appropriate end points.
And those endpoints have to be appropriately robust for us too regularly.
Attitudes based on goes on variable.
So this is kind of just this is your basic toxicology course slide here but just think about the whole concept of toxicology.
And if you haven't heard us before, maybe you can remember today dose makes the poison. Those next to the poison.
Very simple concept. And then environmental aspect.
So there's no exposure. There's no risks, right? So, we deal with this all the time.
That's why we test environmental media.
To assess the exposure, and then based on the numbers we get on day, now you can determine, if there's a risk or not.
However, these three insert.
Very, very important to remember. Those three flavors of dose response relationships.
On the left hand side.
This is the concept of linear, non trash, all panels, so, essentially, there's always some type of response, with increased thoughts.
This always something like that. You know, explain the importance of that in terms of MCS.
Second one this is the ... calls Threshold.
So, your Ex Coast, nothing, nothing, nothing nothing and at some point, you overwhelmed and now you have an accent.
That's the threshold.
And Elastic whole mess is a law premise.
Does anybody can give me an example of permissions where past dose increases?
The benefit of the exposure also increased.
Nutrients don't have Chromium don't have copper in your body.
You don't do solo. And so that's, that's a really interesting concept.
So I don't think the contact is actually do make you feel better a little get into data, but then eventually, if you have too much drama and too much co-operating to die, then automatically formats keep that in mind.
Another concept also in terms of how the regulations of the Belo is that, it's not a simple system. Where do you get exposed, and now you say, No, no, no. That's not nice.
There's actually a series of steps between to exposure to content.
And then the pathological outfall, it have to take place almost like a Swiss cheese alignment, then the health and safety will have a significant event, Thank you.
Bodies can really deal with deterioration that the patient breakdown products before.
Those type of explorers are allowed to cause harm.
And this is important because the, the area of tolerances, this is where some of the regulations actually take place, rare, rarity regulations Here here.
And now we're seeing the trend with the ..., wishing closer, closer, and there's something wrong with people off behind them, ...
So there is no permissible amount of exposure PLC for according to the droplets.
Then, real quickly, just to split revenue, I'm gonna spend too much time on it, but.
Another tip top message is that there's the candidate toxicologist endpoints.
And these are what was listed previously by the, OK, in terms of what we know about the endpoints.
But I think, since we are in the business of protecting human beings, those strictly toxic endpoints catch the power lay into epidemiological effect.
Last, last, we gotta go back.
That zone of tolerance within our bodies and then they may or may not be relevant to what we're doing.
And we are impacting tremendous number of predatory Congress members, if we don't get it just right, just like a Goldilocks.
Here's the concept Motiv actually very important if you read the Federal Register document for the draft, then Seattle's do talk about one of action.
And I think the consensus is we don't quite know what the true mode of action is.
And, this is going to be actually helpful in what doctor Daniel was saying, about the assumption of additivity in the hazard index, hazard quotient.
So, that's going to be coming.
I'm going to move along here, I don't want to lose you.
And, real quickly, the equation for the revision of the risk based water standards. Fairly simple, reference dose is the key.
The drinking water intake, which is a standard, and they're out the source control, usually, so how much off the bus maybe allow are used to be exposed to the water, or other sources.
That's another constant here. So, real quickly, here's the table you saw before.
The main message here, this as follows, those limits have evolved over time. They were high. They're a little bit lower.
There were real health advisories, and now we seem to be itchy back up on that.
There's, there's that pendulum effect.
And, as I mentioned before, EPA State, P false.
And we saw there is no safe amount that we can be exposed.
It's a zero, it's not a numerical Z zero were then the whole concept of positive X Y.
So, moving on to a very important slide, sorry, mention, and EPA's declaration that there is no safe level of performance levels, read the words.
Someone asked: Is it a consumer?
Well, there's nuances how we define personage.
So in the language IP is used.
Paula, there's no say of this likely, and I repeat the key word lightly, Shimon Peres two mentions.
And this is based on Human Kidney Academy observations and highly exposed P fast manufacturing workers.
Remember, dose makes the poison.
So just because someone's responding fast doesn't mean that there's always the response of peoples.
In this case, the data on humans, it was based on and unusually high exposure levels of human beings that is not representative of the general population.
Keep that in mind, yet the regulations will apply to the entire population. So there's a disclaimer.
Where will we measuring and wondering?
And then, for P, false.
And this is extremely troubling, and we have commented on it on the one of our coalitions who belong to.
Is that P false?
Uh, EPA's declaring us are sin of Jan.
However, there's no strong evidence to support that, and, worse yet, it's only available on rats and only highly explosive. So and bar mentally, irrelevant exposures.
So this is there.
OK, I think doctor K also showed this, the whole concept, of how, the community supposed to use the hazard index.
So, hazard index, keep in mind, this simple addition of hazard potions, so the cautions. For each of the four, non carcinogenic assertion not be fast compounds.
A simple fraction, you take your word concentration, over a risk based access to reference concentrations are each, and you sum them up and determine whether a summation H X less than one.
The problem is the classical risk assessment and toxicology, are you to be able to use this metric, you have to ensure that all these four contaminants Hi!
System system effects systematic effects and they fit that dose, Additivity, Moore's Law And, all right, and this should have the same on much.
So I don't think in EPA's supporting documents, data acquired was, I think, what EPA saying, that, or time being, we'll assume too, but that's, that's still to be worked out in the draft.
So moving along to the some of the basis or the each P fastest persistently basis looking at an apples and oranges.
one thing is, is saying that, Oh, we can all the math facts, But the problem is, as doctor you mention, and I'll just show you the tree, the tree of pathos.
They're all different.
For example, even year and the store compounds, we have a long chain, short chain, short chain, and the sharp change.
By virtue of that alone, that's the toxicologists assessor.
They cannot, and they didn't. They are not good candidates.
They're not this, OK? they're not necessarily saying, so that is problematic.
Not a problem that we, as such, stores have in order to be representative of facts of human beings. We need epidemiological study.
Rats and mice are suitable test subjects, but for anyone to impose regulations on community, just based on that, it's troublesome.
So each and every one of these compounds that's listed here, it's it's based on laboratory items, not actual observations to do, and then also know the the great magnitudes of safety factors.
So again, there's a lot of uncertainty there.
And this is not a snapshot to the point I'm making.
How many of the existing regulations and some of the states are listed for each of these candidate endpoints, how much data we have on human studies versus animal studies.
And you can see with a quick look with your eye, most of Brown.
What it tells me, also toxicologists, we still have a little bit of ways to go in understanding city of human beings.
Therefore, regulations are still a little bit early.
Then, this is an interesting and important, also, pie chart is that, while we're regulating heavily the top water drinking water, in fact, most of our exposure as human beings to other sources, including batt.
I don't think there's any regulations on the on the streets right now that look at levels of PFAS in color or powder.
That's not the way it is.
You can see there's another disconnect and little tension.
Then, I'm going to spend too much time, but there's there's really implications.
See also on that promulgated.
And, essentially, this is going to be quite expensive, quite problematic, in terms of implementation on the on a user.
And I think, Dawn, we had a little discussion with all shandy about the rebalancing between the state and federal regulations.
So it is already there, regulations out there, and they've written into the rules. Now EPA is going to have a number that doesn't jive.
Or that's not protected.
They're going to have to come up and Tardes.
So here's the top three takeaways. How are we doing on time level?
I didn't get us back. I trashing the. hectic time. OK, so monitor monitor activities.
Many of the authors we're presenting today, Be aware of what's going on, because it is a fix express train on that one.
Things change constantly. In fact, there's still docket available until the end of this month on the MCS.
So if you have a chance to look at the comments and contribute, that's really a good way for EPA to get maybe.
Re align more with the scientific understanding of people but also, other outputs: ... Nation that's coming biosolids, risk assessments.
Analytical methods: there's a lot of moving pieces to keep a trackball and then any end, I think there's going to be more regulations at this time or additional number of diverse compounds.
So stay tuned.
With this, I'd like to thank you for your attention and not.
OK, thank you.
Alright, so our next speaker, we started to call your last name.
Good research and development with a laugh, graduating from Oklahoma State University. In Chemical Engineering: 2001.
After all, the graduate research in Flux will seek the fluorine Nation reaction.
Joining Live Our Lives, following graduation, me Chad has contributed to the syntheses. interesting.
Matthew is for P Foster Mediation section which develops and ... design for selective capture.
so P five Celsius.
Oh, changed a little bit there. All right, out front. Because I know we're behind on time. This is going to be the big short consequences solutions. For short chain fast, I'm going to be going over the implementation shortchange the bus with You. All know that? You've noticed, especially say, Doctors.
Eats presentation that the concentration of all a lot of these products and the competition is changing over time, and this is kind of dressing why that is what you can expect to see from it and the implications in the future. So, to go over what we're going to be looking at, looking through the history of a subtle, little bit, some of the implications and some efforts to address these problems, including ours.
All right, I'll go over this quickly because you all have this impression Y now. Also, just add this off for those of, you know, better those type over there. She usually an Ionic warms. The earth is here.
So, everybody knows this class.
The liquidus, they're useful to persistent. We have an idea of some of the places that these products are used already over it. And so much, you guys, Aspire grouping and sealing, mental treatment that came up for a bit of oil and gas applications, it's very useful for drawing extra stuff out of wells and whatnot on reproduction. Nobody has mentioned that.
You know, most buying properties are very useful for making polymers of certain sizes after differences between long chain, shortchanged chain length, obviously. But these raises legacy and emerging are also here because the total length isn't always necessarily indicator which ones are older. And newer you also have deliberate branching structures, although some of the legacy ones, also branch just as much, and also certain functional groups.
For instance, you can actually come up, or, there's, your portion here, isn't common law, such intellects basis.
So, as far as the history, we can talk about the status quo, just a second, and Andrew's presentation. You mentioned that stuff hasn't really changed up until about the year 2000 so from about late thirties early forties through 2020. And by legacy were mostly French long chain P, Boston people, especially that. We're using a lot of stuff and for a lot of good reasons, mostly made. By companies like three M, dupont, there's also ... app and more spinoff.
They made a lot of P passes as well as an example, and the formulation of this has actually changed over time. Just an interesting note. Usually legacy passes. Now it's based on a, yes or a derivative. Weren't really required to be tested for environmental impacts Wasn't fun before production anyway. So, they were usually that really, they were very useful and profitable.
It's pretty easy to use.
So, early on, there were some causes for concern. They showed up mostly from internal talks a lot toxicological reports at these companies like say for example and they were noticing accumulations of ... in the environment like say bodies, water and also in animals which isn't necessarily alarming, but if ahead at least showed up at multiple points of course decades.
So, by the year 19 99 or the year 2000, the EPA had been approached with some of this information and they use their abilities under the Toxic Substances Control Act to establish regulations established. That thing that happened to this document right here is all a sir, which refers to be.
New. Significant new use requirement. So, basically, if you had a significant new use for these products, we have to let the EPA know first, and they would sign off.
Oh, so, these conversations start taking place.
Now, and because of these conversations and the data that these companies are starting to last internally, they started to abandon these legacy fast around the year 2000. Most of these companies are trying to participate in voluntary phase outs because they can kind of see the writing on the wall, as far as what the EPA was intending to do, it's information that was starting to become available to them. And many of these producers would go on to participate in stewardship programs.
Like the when it started in 2006, for instance, there were eight companies that were part of that, and putting three M and dupont and also BASF. Um, so, the problem is posed.
We're phasing out like CP bass.
Now, that's the choice that we decided to make, but it's a little bit of a business problem is posed with that. We really want to be able to continue offering these services for these products and for these process streams that are useful and bearing P fast. So, now we need a product that can build our niche while also not making the EPA. So, it should probably be back then should probably be hydrophobic. most Phi M Persistent. Because those properties, if you'd like to see, but any boss or people, those out, by accumulating. Because that was the first problem that we noticed shouldn't be a hazard. Which, at this point, they didn't really have an idea of what the toxicity look like outside of tests that have been done on animals that extremely high concentrations. And if you inject around the grand anything, that was probably going to be changed. And it would also weren't persistent, because that was part of the problem initially. It was accumulating in the environments.
So, you'll notice that the persistency, it's kind of a bit of a double edged sword, like you don't want it to fall apart, but it would also be good to just stay around forever. So it's complicated.
The solution that was settled on was maybe a little bit too simple, but it was effective, for the most part, you can just make them sure, because they're shorter. They should be more mobile and water less likely to attached to substances like same protein, especially bats soils In life and other environments.
And due to being mostly identical, most of the properties, so there's more or less, just hot swap them into the same situations that you hadn't been poor. For instance, in Scratch, are, in that production. They just the Boston by, say, with the f.b.x. file path delay, and still works OK.
And the result was that the fast were babies out with this next generation of short chain alternate.
So, with the adoption of the short team, be fast.
A large variety of them are introduced to the market and subsequent environments, and part of the issue with that was the fact that there was now this old that was provided for this niche. And a lot of these companies, which were now producing an opportunity to establish IP and to offer new things to the market.
For instance, earlier, the whole idea of trade secrets of come up and things along those lines, this is part of that issue. And because of that, a lot of these details aren't necessarily public.
Um, and this exacerbated, the difficulty of collecting data and doing research on all, these, is the best one, because they were new. There just wasn't as much time available to do these things, and to, because a lot of them weren't made publicly known until after they've been in existence for awhile.
The research that's going on in time wasn't term, was and is. So, now we have new problems are associated shortchange bass. Sadly, the resolutions that were offered business problems didn't actually translate to the public and environmental problems.
Yeah, they could still have the products that work, but be assumed benefits that making them shorter, didn't actually pan out as well as they expected.
Um, and as a body of research started to catch up, we come to a general consensus that they are so widely distributed environment.
They're still amount of various concentrations and wildlife, various concentrations people found to be similarly toxic, an animal testing and make some more notes on that. Android already brought these back and found to be associated with health risks in humans and certainly, a sufficiently high concentrations.
So, all this is to say, the problems that are associated with legacy be fast, had not actually been solved.
And then we get to the issue of the P bass boom. So earlier, I mentioned that the whole and there was an IP opportunity and now, a lot of these P bass producers are producing a lot more fast. Because it wasn't just primarily P Boston people waiting for the opportunity to introduce new market, and get them into certain spaces.
And because of that, we have a much greater amount of things, showing up in a much shorter time, than we had four P Boss Hand people. Remember, the fastest in general? They've been around for a long time. And we really didn't start getting a whole lot of public research on this up until the year, 2000.
You know, it took 60 years, even start catching up to that, and now we had 20 decades after it already started. So we haven't had very much time to track things like liberation through the environment and long term effects on health, the environment.
So, animals, say, fish, wildlife, air quality, water quality, and the effects of bass had bought, or saint, long term effects.
Um, this number is actually a little bit outdated. But that just goes to show one of how changes in what we're defining is fast and kind of change things.
More than 3000 P bass on the market were deliberately used and there are many others which are not known or understood. And by that, I mean that a lot of these compounds don't actually have mass numbers. So they're not well, database which is a huge issue. That also goes into the whole difficult to track as far as things on MSDS is you have the ability to withhold certain information for various business.
Tom, split a huge gap in the research, which is a big problem.
But, before we assume that there's a problem, you know, of course, we're asking, how to solve a problem.
Is there a problem first? Right? So, there may be all these shortchange floating around, but maybe they are in the better off. We're assuming that goes with that. We know it's only been 20 some years. So, while A lot of the research that has been done is suggesting that all that the vast do have some adverse health effects for discerning individuals'. You know, you, I, we might be under the impression that the toxicological data to suggest this isn't quite good enough.
And if you're of that opinion, I would posit to you that there's actually a more fundamental problem at a systemic level specifically because feedbacks are so persistent. And this is the problem it's actually been exacerbated by shortchange the best.
And if we don't have a major intervention, it will become fall, if you believe that it is.
So before we get into that, I'm going to have a little bit of a primer. You're going to learn some engineering principles today, so you get to walk away with something that you can use in your daily life. You think about the kinds of things I think, probably get all this already, but we're gonna learn about networking apps.
So, um, before we go on, we have this idea of the system.
So the system is a volume, as in space, under consideration. And it can contain a quantity, like I think, you know, you can think like apples, bananas, water, whatever. And it can produce, as an going into existence, or destroyed, and or exchange that quantity with its surroundings. And another note, the system to be broken into subsystems, which are themselves systems and you can use a universe.
So, I can take this system, draw an extra boundary in the middle of say, OK, now I have two systems, actually, or I can take two systems, eliminate this boundary in between them, and say, OK at once, that's illegal.
And we also have bounds. To make this easy, you can summarize balance with this little phrase right here.
Some of you have seen this in another form, at least I know we're just short. We're in minus out plus generation equal to accumulation.
So in we'll just see quantity entering the system.
Ouch would be a quantity leading a system.
Generation is the quantity that is created as an inquiry into existence or destroyed as an brought out of existence inside the system, and Accumulation is the quantity presence in that's for accumulating and that's in the case of flow.
So here we'll have a figure to imagine this arrows being in.
This arrow is B out the whole bossed SP a source for a state which I'll use circle or an office market source or sink This is tough place where something is being created or destroyed, and then accumulation, which just represents what's inside a box.
So, for a simple example, We can take my bottom, and if the quantity under consideration is P fast, we can imagine that it would be the best that I can do. Save or food, or drink re-imagine out as being the feedbacks that excrete through the typical methods. You can imagine a source for a safe as being P bass generated or destroyed and my body ...
certainly isn't made inside of my body, and as we know, it generally isn't Detroit inside of my body, and then cumulation, fast, that is, say, attaching to my origin and not in my body.
But if the amount was showing in, the amount that's coming out is the same, then the amount that's inside of me.
And that's important.
So, now that we know what a system is, balances, we can talk about nodes, Networks, luckily there are basically different words for the subsidy, we've already been.
A network is a system, which has a set of inter-connected systems, and a Node is just a subsystem Internet is inter-connected, substance mission definition. So, here's an example network. As you can see, That would be this whole year.
And we call it N one, node one. And node 2 and 3 are 3 or 4 node for. Now, you can see these arrows here. International flows of something, a consideration. Let's just take one example.
So, maybe your state or something like that is being here and water will flow out into N three, Then it may blow out of a three into M one or M four. and managing, blow out and for vaccines.
And with these arrows, you can get kind of an impression of certain characteristics system. For instance, water ends up an N one.
It doesn't meet.
And if water is an end to, it has to go to end.
Now, you may be asking yourself, well, how do I know how much moving along those arrows. That's the hard part.
And this is a systems analysis 1001, figuring out what exactly, these arrows are as every other number in those parts graduate school board, but this will be good enough for looking at the problem as time points.
So, the PTA's problem, as a network, if we consider a network for key, vast nodes that we're concerned with, would be the producers, the industrial produces P bass, Jack is the source. So remember that generation term that I was talking about before?
These are bringing peep asked into existence were once there wasn't now there products, products or services that can be in services process flow or whatever or stationary which incorporate heat maps.
Then we have the implant, this is very abstract.
We've been talking a lot, and a lot of things that contributes to more granular impression is, like, what these things mean, like, say, in water treatment process or whatever.
But, in general, we're going to talk about the environment is being living and non living things people interact with, or uses a resource. So, big air, soil, water, plants, animals, basically anywhere that in any of these three places.
Brian, I'll get into something else.
Just then, of course, people, us, like say in our bullets or in ..., which is a place that we don't.
In general, we don't want it in the environment, and we don't want us. But we do want to hear useful here. And we need to have it here because this is where ships.
So if we can imagine that the best problem is network, we can see that we have producers, which act as source. Then the ...
acids produced ghost products, or that goes to the environment, say, be a waste streams, keep fruit crops, either from flying off.
For instance, you know, if you have cookware and you're not being terribly judicious, my kind of scrape off and this waste or whatever ends up in the environment, then would be environments. It ends up in us, safer food drink, and then come us enough, battling the environment your excretion.
Now, if you're being very careful, you'll notice something very important.
This poll right here because, remember, you can take two subsystems all in one system.
This system, places where we don't want them to be, only has arrows going in.
So, even without all the engineering 1002, the X X X X X, we can notice that the accumulation here can only ever be possible.
And there will always be more, as long as there is a source.
This is a problem.
So there's a source, but because the bathroom so persistent, there's no abstains.
So, the total network accumulation always falls.
And because it's incorporated in the products are lost waste, it will always end up in either environment where people, this is back.
So the solutions would be either you make the same, we just say, you have a means for destruction.
Or you create a new node is an outlet for feedback and MR.
And we'll call this new node can teach, which represents keep acids isolated.
You think about an example of trash on your own. You produce trash and it's in your home. That's unavoidable, but you're OK with the trash being around, as long as it's in the trash.
So you can think of containment is being the track somewhere to put it that you're OK.
Now, if we add that to the network, then we have something that looks like this.
Producers, as before, and vivacity into products, or into the environment is waste, When we also have ..., think of waste, stream treat, right?
And with respect to the environments, we ask for feedback So people can join people back to the bottom, but critically, we now have from the environment's contains, which means that we no longer have that problem only anywhere else.
Yeah, this work, and as a matter of fact, this is actually the way that things already. we do have faster containerized environment with methods like distortion, primarily, GAC, and ion exchange, or reverse osmosis, similar technologies of filtration, for instance, basically, membrane.
Um, Pete best things actually do exist. But right now, they're pretty limited.
either the scale or applicability, or just, and until we get to a point where it's such a good enough to be ... neutral on the whole, we're gonna need better content.
Because the better containers are, the more you can draw away from the environment, Ideally, with fewer resources, if at all cost.
But eventually, some combination of these resolutions will need to be reached in order to mitigate the accumulation.
Got to meet your improved construction technologies. Should be fast neutrality.
Improve the batch recycling, to eliminate the need, for sources, at which point, sources, no thanks, fixed inside the system.
Or, we need to find an alternative for E pass use altogether. Find something else to build a niche that doesn't have the same problems.
So the same solution, You have the same general layout as well, but now we add the state to contains.
So once we get P fastened to containment, we have the way to destroy it.
As long as the source is the same as the sink, this whole environment is keep asking.
There's more people being made, and there's some P bass that's going away. But the amount of PCAST is constantly increasing in the world.
Or you have a resize.
You take away its source.
Now, we have no sources and we have no sense. So again, the whole world is keep as usual.
But critically, if we have some way to take P fast, it goes into containers out of containment.
You get it back to the producers.
Then we can still keep apps just support and we don't even need to make it. Or the amount that we didn't need to make could be suitably small. Let's say, we can make a lot.
Again, it's a combination.
Or the solution where we just develop an alternative, you don't even need producers and not use.
So, now, we just have the products that already have ..., which will probably continue to be used, because, you know, why did a job?
Um, going to the environment, people, they'll just swap back and forth between year until eventually, they're all. Or most are going to be the idea.
So shortchanged ...
actually pose a problem for all of these solutions because of the increased solubility and their decreased by up, which is the exact reason that they were often for in the first place. They are actually more difficult to contain files.
It's harder to get in soil because it's harder to get in the body.
Generally speaking, it's harder to get in pretty much anything else like water.
And a lot of time because the instruction technologies are actually limited in their ability to memorize shortchange the fast. Not all, but a lot of them will go through a process where the chain length is decreased one step by step by step.
And many of them will stop or slow down severely once it gets to about 4 to 2.
And because of that, they stop at 4 to 2.
Now, you've taken a long chain and made short and the effective shortchange the bass. Again, because they're more difficult containerized. You can imagine it as putting a resistor, right? And you can think of that as being a resistor. If you're familiar or clogged drain saint Plaza.
So, yeah, flow reduction.
And because of that flow reduction, you actually have an increased accumulation down here.
So, we have a need for better containers.
And we, as, you know, society, Industry government, whatever, work towards more sustainable solutions for use or disuse and cleanup.
The containment strategies are going to become more and more important.
Any instruction based approach is going to require ... be sequestered from the environment.
And probably concentrated, not necessarily, but most of these technologies kind of depend on having certainly high concentration to work much.
Any recycled waste approach is going to acquire ... to be sequestered from the environment into the container and also sequestered from the container.
Back to the producers in some type of way.
Ideally, the material will be gentle, and even if we stopped using cheatgrass, we do have a requirement to remove it from the environments.
If, you know, we want to mitigate any of the effects that already come to experience, if we come to these things.
So this containment is the ultimate limit to the effectiveness of all these solutions reasons.
So as far as relapses competition as well.
And while kind of the existing containment technologies can be used asset for GAC. And I actually used both in analytical context, as well as in cleanup contacts.
They have a number of divisions are absorbed. It's like GAC an IX, mainly non-specific. ...
are great, but they're also used for that, pardon me, to address a large number of ... dyes, various other compounds that are found in contaminated water.
Can be tended by non P bass over not strict of course, concentration, but it's something new and ARO.
Do they usually require large operating costs because you're pumping through these high pressure Delta and they add small throughputs or one or the other?
And in many cases, they require equipment isn't available to a lot of say, smaller.
There are infrastructural aos there.
And as I believe our coffee, you brought up earlier, there's actually a little bit of a problem with the concentrate: you need something.
And a lot of the times that concentration isn't necessarily in a specific column.
Um, so there have been developments in the way a novelist orbits, but most have the bulk of their mass consists of synthetic research. So what we've been working on some of these submissions.
So, we're all people use case of a typical solvent. Something that hasn't similar method of action as a GSP, whereas, which means that it could be more easily incorporated into existing structure Either swapped out with or used in tandem with the GAC, or I asked this campaign.
The majority of the mass of these orbits is silica which limits one resource costs in terms and to be literal costs. Silica is relatively cheap.
And we also, in many of these disorders, utilize Floorspace interactions, generally speaking, related compounds tend to Bazel, ... compounds.
They have high partitions in seasons.
And using those in tandem with, in many cases, either ionic, as a pure students second, or otherwise polar.
I think your interactions with water soft costs over the non florida asylums, compared to other sources. And, in particular, the polar area allows, for international waters, albeit stuff, in spite of the fact that, large tables are sometimes.
So during the screening of our candidates, we noticed one of our surveys, MBAs, who's actually doing very, very well with groundwater samples that we collected from outer space. We love him very much.
Even more interesting, the short-term performance was actually quite high.
It's a bit more difficult to see on this figure moments, But if you consider a lot of these bars up.
And just as a patient, you shouldn't necessarily take this vacation usefulness of ... general.
There are already well. But at least for the experiments, if you were to be on the water that we treat, the GST and IX is comparable to some at least with respect to some of those be fast. But in other cases it's not perfect at all. This same data, you can see maybe a bit more data, we in this figure right here.
So, this is a heat map, and just to explain how it starts, This, you'll notice these ... is here on the left.
And you'll notice the sorbent here at the bottom.
And you'll notice that each of these squares has color, and also has a number.
And just to clarify, all of these are percent, as in the amount, the best western water was initially measured in water.
Um, you can see that the rows are representing the removal of this given P fast by the students. And similarly, the columns represent this specific deep asked by the students.
So you can imagine that light colored columns represent good stories.
And light colored rows represent easy that. Conversely, you can imagine this dark colored columns represent poorly, and dark color rows represent problematic. That's now, if you're familiar with the literature, you know that the shorter chain ethos, generally speaking, are more difficult.
And we can see this worn out, and this data notice that ..., which is a work hard and fast, a lot more dark, spots compared to ..., which is 12, this 10 step.
Which is a 10 CV fast fight, for me, at least in Paris.
So shorter chain of events, right? We notice this property. It seems to be working pretty well, shortchanged fast. So along those lines, 1 test 2 of our Kansas with less conventional next generation, ..., remember that one, that either in or out here and we also tested what's called an ultra short chain, bass, piano PA, that C three, which is out.
Ignore the art asset type O. So over here, we can see the importance of GHD IX, 78 and 12.
Now, a very important thing to know about these two, in particular, tend to be 12, is an analog of MBAs, the non learning.
So, we can see from this data, or our nation seem setbacks, the ability to absorb shortchanging.
The bass in particular, very particular meat, is right here, but not as much of a difference Js, which is five, or six actually.
So, thus far we've shown strong potential is an actionable solution is formed on a variety of conditions, particularly highly acidic conditions to perform well following five regeneration, and is performed well for all the best, use it off to run through this pretty quickly. We have performance again, all this for some people, at different places, at different times. So here we can see at approximately PH, seven untreated water around 30 minutes versus two hours, and here we can see at PH two.
Now you'll notice PHQ two ...
performance of 30 minutes quite a bit lower, but by the time that it gets to two hours, it's performing on the order, which would seem to suggest the acidic conditions slope this is option, but overall, don't reduce the opacity, or at least the equilibrium.
And down here, we can see the data associated with our generations.
So we use the material once this long groundwater, By the way, we use the material launched on groundwater that got an office air force base.
Then watch this material with serious solvents, regenerated use again, Branch. Be rich.
So, this material used to wash five times and overall performance time.
Uh, reduce that much, At least with respect to people, Particularly, people, drop out of the team.
But that's not tariff to be able to re-use the materials so many times, as well as capture that can foster a more usable form, as opposed to having a few parameters.
So in the future, as we keep working on ..., incorporating it into say environmental remediation efforts, municipal water treatment, or even at home use, like a bird a filter or a point of entry system outside of your house, water softeners type for individuals, families, businesses.
Our current efforts are pointed towards research and one-off Mormons in a packed bed absorption system. That would be the kind of thing that you would expect to see if you were using, say, GAC treatment in a water treatment system, either at a municipal level, first level.
And also, we're working towards furthering research into generation shapes. Like I said before, we've been using it for generation. And we know that we can use it multiple times.
But trying to make that process a suspicion as possible, on increasing concentration of the material compared to the influence that originally loaded and maybe to look at it as being a source for incorporation via that research.
To limit the need produced fast for those scenarios where feedback is, like to think that they're going to go out of style until we can make something better, that isn't Florida, which might take quite a while.
So takeaways, the password can purchase, but they're very useful.
And even though we got this regime placements, they didn't actually make the problem easier to solve, and the auditors, all. Our current strategies are all dependent on our ability to remove the bashing the environment and isolated in some way.
If we don't have access to it, you can't do a whole lot and it would be better if there were costs and current solutions are used, Great!
But the expansion of the P, fast into greater variety and in greater amounts as well makes it very difficult to manage shortchange compounds and it makes the current solutions. less less attractive as we look at this problem. Certainly.
So bottom line, we have a responsibility to ourselves to try and clean up our messes. And I say this personally, I'm somebody who works in floral chemistry. I have for several years. But we need to try and address these problems.
In other words, forest mass. So we built them off.
You have fun.
We question up our last speaker, we have one more question.
OK, All right, our next speaker will be online.
She's found plain fabulous.
DOE is the National Director for ...
Filtration as the Technical and Sales lead. Imagine somebody Hands and Water Treatment program for the plane pebbles and remains a therapy group.
They have found over 35 P slash S for the treatment right project in North America, and it will bring have 25 years of experience in the environmental laboratory and remediation Felix ....
Analytical results, they evaluate the options what streets means.
Utilizing varied medias, retreats means equipment.
So achieve project objectives having walked us, AGC, MS, and also most.
We simply asked LC MS ... violence.
She believes in the importance of we've seen the projects as a whole.
I'm suggesting the most variable testing method at the beginning of the project that helps determine the best treatment train and media for complex waste streams. So, informing clients on their options.
We'll find out equalization, obvious paints meet you.
Holds a BS in Chemistry, geology from Bridgewater, State, University.
I, can you hear me?
Yes, we were in Nepal.
That's not enough for you guys tomorrow.
OK, times good, OK, wonderful. Thank you for having me. Yep, I think what's going to happen is that I'm going to tell someone to advance the slide again, just glad to be here and listening to the other speakers. Very interesting and development happening right now. So the format found very, very interesting. I guess you can go to the next slide.
OK, wonderful, so, really, the main focus of this was going to be a practical guide and information as treatment and disposal professionals. I had a slide here from an upcoming National Groundwater Association, White paper, The Carnival, Treatment disposed Decision Tree.
Understand the limitations of current analytical tools for PFS identification.
Managing, I know, known evaluating piece as treatment and disposal options is giving you some tools to look at some criteria for making decisions, considerations for formulating a treatment and proposal narrative.
Then, I'll talk a little bit about our approach, which is skid Removal, which is separation consecration isolation and then the decision about where it's going to be disposed upright. And then project consider project considerations there are examples from higher concentration treatment.
I thought this would be really helpful, um, talking about a different qualities that approaches have right now. So talking about Parvin being the most widely accepted treatment methodology. And that's really because it has really been used.
Filtration and purification of water since basically the Roman times. And we have been using it in our drinking water applications, the OCS and many other different contaminants. So, in the beginning, and I say the beginning, after you see M R three, and it became, you, know, the forefront of that is impacting drinking water 2016, and beyond probably, for the first three years, it was mostly carbon application.
Then as an ion exchange Resin became the second most widely accepted option.
Personally, I like a carbon resin, can combination, and I'll get into that a little later, and then RL and reverse osmosis membrane technology is absolutely wonderful. It does a superb job on the short compound.
The problem is, is that even the most efficient RO systems have a reject water and what they are rejecting a lot of times is salts that are in the water as well as other contaminant.
So, what happens is that you wind up having this more concentrated brine is not amenable to standard treatment system, So then you have to worry about, you know, let's say you had 100 GPM system. If you had at 90% efficiency, it would wind up still having 10 gallons per minute of reject water content. So, it's just something that you can take a look at and talking about considerations for free job. Next slide.
So I use this slide a lot, and I really think it brings home to people limitations of our current analytical maps, right?
So, our CMS PIMS included 5, 37, 16, 33.
These are all very targeted analytic methods using LC MS biomass, and that's really, like, three aspects in a row. So it's sorting, sorting, and sorting. So you're getting down to very, very low concentrations for being able to act, and that's because you are excluding so many other compounds.
So it's not like DC analysis, GCM, DCMS analysis where you'd have pequot forthright and typically identified compound.
If you just changed one Laura needed over there on the right is a perforated compound. If you change just one fluorine to paint it to a hydrogen and making it a polish coronated, it actually would be invisible to the analytical method.
I think that's really, yeah, I think that's an important concept for people to understand that we're really only seeing a very, very small subset, right?
Again, even the most most widely yeah, the largest compound list will only have about 70 commercially available standard.
That means we can only see about 70 of, you know, fraud the number of how many defense compounds that are out there right now.
Honestly, we're seeing such a very small subset of compounds and then you'll even know that the 537, 633 the compound lists are very different something to consider.
And at the same time what's happening is that reporting limits are going down for you CMDR three in about 2200 parts per trillion that wasn't accepted reporting limit. And now we're going to be heading into ...
five, and we're talking about single digit reporting limits. These compounds so we're going down, we're seeing much lower.
And at the same time, the compound lists are going up, so it's, it's best.
Now, how do we contend with all this happening.
Chemistry is pretty much the analytical chemistry is getting to the point where we're seeing sub parts per trillion And then the compounds are going up, so it's, it's really just taking these things into consideration and knowing that, you know, if we keep going lower, we're gonna be seeing a lot more heads and without people understanding, you know, ambient concentrations at ground contamination. It's just going to make unknowns even more important. The next slide.
I do this because I just want people to understand that.
I, I really, I have a lot of respect for the PTAC chemistry, That's because we just know very little about it at this time, know, and then we talk about all these things about, you know, managing unknown, upcoming regulations, new analytical tools, and then discovery about PFS behavior, weird. No things smart.
I mean, not even that long ago people at that he's asked was: At volatile, at any, at any time, right, and now we're learning more and more, so, it, You know, the first one, the Blob, I don't know how many people have actually watched these movies, I grew up watching the creepy, double future. And the thing that happened, is it the first group of scientists, they come in. Like, alright. We know how to destroy it. And what they do is they do something to it, And then there's 200 blogs because didn't destroy it, right?
I really try to treat fast, respectfully and not think I know more, and it's going to be known to us in the future, right? It's, it's still an unknown commodity in many respects.
So, how do we deal with? So we're waiting for new regulations to come down.
Especially, we had that document term guidance on P fast disposal, and we really didn't get a whole bunch of answers. What we did get was a whole lot of unanswered questions, so how do you establish a P fast policy in an environment when so many unknown?
You have to think about an app.
I'm established federal state guidelines at potential future liability, market competitiveness, public awareness, and cost. And then, someone else had said, when they saw an aside, recently, make sure you add safety in there as well Because it's really true. We have to be safe, we have to be conscious of what we're doing.
With that being said, you have to take all of these things into consideration. How risk averse do you want today? Are you looking ahead to make sure that what you're doing is not potentially causing a new problem that we're not recognizing yet. So yeah, you have to think about without if someone tells you that it's not regulated, you treat it as something. Potentially that could be or do you or do you have a more lax policy because there's no, because there is no real federal guideline. Yes.
So, that's, you know, because if people have to figure out what is most important to them, and their policy, internally and externally, Next slide.
What we did get the EPA's interim guidance on PFS disposal was that it was really just an outline for practitioners to use when deciding whether to stockpile material.
I consider disposal or destruction option, so, you're weighing liability against tested technologies, untested technology, space, all kinds of things. Capacity, capacity is huge, because if we decided we're going to landfill everything, or we're going to incinerate everything, and we have to realize our, our existing structures able to keep up with the demand of having all this material go to those options, right.
So the evaluation criteria for evaluating a P fast treatment or disposal option would be viability. Is it viable? Does it have a proven track record?
Is it accepted by regulators in the general public?
These things are huge, because what happens even if you do get something approved, you still have to go through the approval of the public, right?
Are they going to feel that this is something that they're not going to be posing any unknown risks in the future, then levels of permitting and oversight, cost, speed of deployment, results record?
Is there another waste generated, and is this scalable? Is this ready for implementation on a full scale?
So all of these things can be weighed, and you can compare your options to make and establish your own no guidance in what you're going to do for a policy.
So, next slide.
I'm giving you clean harbors treatment and disposal policy. as an example, we've decided to be very, very, what's the word risk averse and conservative.
We will treat P fast in water.
And by doing this, we we use the, if it doesn't fit the skid model, then we're most likely not going to be considering it, right? And so, what is that?
Where we're separating?
Contaminants from large volumes of water doing so, we're concentrating this, these compounds onto a relatively small quantity of media, where it is isolated and then at that point, people can make the decision of what they want to do. with that spent media that has concentrated and isolated these contaminants onto it. They can choose to stockpile it. They can choose a number of different options.
as clean harbor's if we're working on a project or even internally, we send media and soil for incineration.
Current exception right now is the DOD moratorium on PFS incineration from the Defense Authorization Act of 2021, solidification or to our closed loop landfills which are subsided. Subtitle see meaning hazardous, and when we say closed loop, it means that the leachate never leaves the the custody of Clean Harper's. So there's no third party in any material, and we assume all liability.
The options that we do not do right now is subtitled D landfills, and what that means is non hazardous landfills and carbon reactivation. And the main reason for carbon reactivation is because we don't, we don't own carbon reactivation facilities. And then other destructive, innovative, destructive technologies, because they are the criteria that we talked about previously, we have not found one that Knits meets that standard of criteria that fits into our own policy at that time.
And even deep, well injection, we're not considering at this time as well, so this is an example of a company that, you know, what the decisions that they're making and how they use those evaluation tools to create a policy until we get established federal guidelines.
So next, slide.
Again, just to talk about this. We're separating this is again. Scared.
And one thing that I do want to highlight is the reason why we really follow this is because the objective is, is that we don't want to we don't want to transform, right? And we don't want to liberate.
So those are two things that with no newer technologies, we really don't have information, if we're actually changing these compounds or liberating them.
So we feel that this particular method allows us to be very conservative and we're concentrating it. We're not changing it. We're just absorbing it by ion Exchange, A clay or a carbon.
So he hasn't, you know, concentrated, relatively concentrated media that we have to make a decision on. Next slide.
So, examples of project with varied discharge criteria, and I will tell you and hearing everybody talk about what regulations are and what the states are doing.
Regardless of that, the people that usually make the decision about where this water is going to be accepted to our other wastewater treatment plants. And even if there are established limitations by a state, they have the final say to be even more restrictive, OK.
So, what that means is, even if there is a set number, whoever is receiving the water will determine what that criteria is. And I will tell you that many, many, many of our projects now, it is not a number. It is non detect. So, what is non detect mean?
That's a project objective that you absolutely have to get established, right?
So you get all the parties together, and you determine what does nine detect me?
What is the compound list? What is the reporting limit?
And for me, the conversation that I have is that, OK, let's look at the laboratory that we're utilizing.
Let's look at the compound list and then, you know, instead of going to sub part per trillion, we say what is the reporting limit that you have for your method blank?
So if you're running samples and you're running batch, blanck, what is the number that you say that your blank is clean? Then that's the number that we that we try to use because otherwise, you know, why would I be holding my water to a higher standard than a lab would be using for their method blank for the day? So that's kind of why you have to have these conversations to get disagreed upon, right?
The type of projects that we're doing, except for one of the drinking water systems that we have, which is 750 GPM carbon resn application where the income and concentrations are low part per trillion.
We're dealing with current, per billion, part per million concentrations, coming in for influence, from Remediation projects.
Fixed volume a triple F releases, Um, industrial releases for cleaning facilities, or fabric finishers. These are the kinds of things that the, the influent water that we're receiving and having to get down to or below drinking water standards. Right.
And so, this is, this is where we are, where we're taking water that's basically industrial or very highly concentrated, and then having to have the same discharge criteria as drinking water south.
Just something to consider.
And I am a big proponent of treating highly concentrated waste streams, and I think I have a slide in here that will demonstrate why I feel so strongly about that. So, next slide.
So how do we do this? This is just showing.
Let's say that we have an industrial application.
You have to, because we're waiting so long for our analytical results, sometimes it's two weeks to get your analytical results back. You are doing sequential removal, right? And so you're monitoring between the beds so that we're dealing with high concentrations. You want to change out your beds earlier on in the sequence, so you protect your media that's closest to discharge from getting contaminated. And that's how you maintain that non detect discharge criteria. Right?
By having good analytical evaluation in between beds, and a very good Owen M system, so that you're evaluating, changing out, making sure that the media that you have chosen is acting the way that you needed to, and it's sequential reduction.
Here's the one that, here's a slide that I was just talking about.
We have limited resources. We have limited space. You know, we have limited funds. We can't bankrupt every municipality in, in the United States. If we had to have, you know, just keep putting higher concentration to get down, to treat very large volumes starting at, you know, very low concentrations.
As an example, if you start out with 11 parts per million, influent and your affluent concentration is, let's say, five parts per trillion, look at your removal efficiency, right. It's incredible.
If you, then, you can look at how it changes as you go down, if you are starting out, like, a, like, an average drinking water, and you're starting out with 10 parts per trillion, and let's say that 1.5 is your, is your criteria for an exchange, right.
You're only 85% efficiency.
We have to be able to get the bulk of this material out early on so that we're not burdening our drinking water or wastewater treatment facilities.
What I did was I shown a gathering information for creating a defensible treatment and disposal narrative.
This is something, if you're at the stage, I highly recommend people, if they think at some point in time that they may have a a P fast application.
I would start considering your narrative, your defensible treatment and disposal narrative early on because then you can say, OK, I'm looking at this option, this option, this option. You could write them down and then compare the information that you have about all this criteria.
And then you basically have a written narrative of why you made that decision.
And until we get these in until we get final guidelines, this is something that really helps people determine what they're going to do.
Stockpiling know If you don't have that option, we have, seen situations, where people have stockpiled materials. Something happens and they wind up having a release.
So, you know, it may not be the answer for everyone. So this is something that, as a tool, as a practitioner. this is something to get yourself started. And then once you've got this, take a look at what they're offering right in your disposal option or you're getting a certificate of distraction or you're getting a certificate of disposal is the facility permitted? If it is permitted Is it does it? This hazardous permanent, what similar contaminants are there, you know, And what's the, what's the level of oversight? Just, just all of these things that help you create something. So that if you, you know, you put in a position. You have to make decisions without guidelines. You can, you can explain and show the information, that helps you make that decision.
So, let me say, so another side.
I learned really fast. I was trying to make up time to do that. Did that work? Yes. Oh. Yeah, no problem.
The years from Albany, and, uh, if you have questions flooding, you can ask and Hey.
All you have question, I can help you guys.
It's been a long day.
Oh. Yeah. Sure.
Amy, do you have any questions from you?
I have a couple of them. Let's see. This goes back to the beginning of the day. How does ... designation relate to articles? If an article contains a circular chemical is the article now a hazardous material and handled as a hazardous waste?
Hazardous waste under Red Brown.
I can hear you guys kind of, but it sounds like you're very far away. It's kinda hard to hear you say.
Yeah, so if a contaminant is, EPA says, that's surplus hazardous substance, that does not make it hazardous waste under record, AK is in their roadmap. They are talking about that, but they have not made any proposals.
Introduce I'm Amy Britain. I'm from the implement quality.
Thank you, Amy.
Thank you Annie. Um let's see. Another one is TH sheet that breaks down and wastewater sludge are still unsteady it with these roles with the city or the industry's be liable for the long term effects.
Was that specific person wasn't just a general, think Don would have been able to answer that, but he's already left for the day? Oh, my apologies, I didn't know he was gone. Yes.
So, anyone wanna take a stab or shall we move on to the next one?
Oh, move on to the next slide. Right. How accurate are parts per trillion measurements?
Are the labs who are are there labs that are ready to do this?
Absolutely, yeah, we're running controls or exploring limits are no single digit.
I also say that that's the Oklahoma State Environmental Laboratory Division is it correct to do is to be fast and for the wildlife and we'll be starting that with our lives Staff wasn't monitoring in the air.
We have our person here from the lab to rest.
Cool. I actually expand on that question.
Yeah you up a little bit I'm sorry do you want to close us up for the NCL I'm sorry detection limits or skills one part trillion is that for every analyte on the panel.
Know like I've said earlier some some probably the less the world the EMR.
Enter 16 3.
Now, remember, I think they're somewhere double digits, but I'm open to new baby.
And you're using the same.
A very safe base case.
Kind of going back and forth on, clear and how she thinks.
Thank you. If you want to go back to the previous question, I wasn't quick enough on draw but the question of whether or not we will have a liability the present produces some transfer of the landfill biosolids.
Um, the answer is, yes, send your joint and several liability.
Each of those parties can be brought into the light.
That's part of it in the apps that have clearly defined culpable party circle.
The ball cannot just go up not application basis.
That's a joint several, your responsibility, your numbers, and your efforts.
I've heard that there's a lot of active lobby.
There's water treatment, water treatment industry, or landfill loftiest, that are trying to create exclusions. I know that it's really heavy.
Bush right now have no idea where that's going to go.
That's that that's something that's on the table, Uh, that we could see within the circle. Come out with an acronym for that responsibility.
I honestly don't.
Yeah, it's a hot topic.
Introduce five bills related to issues for five different areas in agriculture: water, wastewater treatment.
And so, because otherwise it won't take this job, right.
It goes back to your problems.
Yeah, I saw you unmuted. Did you have some comments as well?
I think goes about the 16, 33, I think most of the compounds on 633 are single digit reporting limits as well, which is, it's pretty, pretty impressive. That's how I was going to say. Thank you, mister Smart there, that was able to accomplish that.
Yeah. I can't remember exactly what our Portal.
I have one more online, and if people online would like to submit additional questions, please feel free to do so. This last question, I believe, is for doctor E the mentioned the EPA prize reliable for people felt bad.
The fire fighting turnout gear has 20 B parts per trillion.
Can you explain the 20 B are billion parts per trillion?
Number more the EPA advisory is for ingestion, why the turnout gear is a solid material is that Advisory Level four the concentration of the waterproofing, applied to the gear.
Did you get all that?
Well, I think, I think, I understand, the question, is, and the answer is: A firefighting gear seems to be a different media and different exposure pathway, at least one seems to be the dermal exposure pathway dyar's slide shell.
That skin contact may result in some type of Transdermal update.
yet the health advisories ingestion badly.
So I think that maybe conductivity, in terms of the ultimate dose, Christy.
But I don't know health advisory just directly relevant related to the matter two plus the fact that indicated that that length is not clear.
Did that answer?
Does that answer the question for that first thing?
OK, I've got a question for Richard. You don't mind it is with respect to these destruction technology is supercritical water oxygenation.
But it has to do plan, or the Colorado School of Mines, where you unmute values, ethics, scalability.
These emerging technologies, yeah, it's tricky.
I've done a decent amount of reading of the current literature on all my stop expert by any stretch of imagination, but as I understand it, currently, a lot of the methods, such as like this, um, are dependent on having very high concentrations. And most of the tests that have been done or on relatively small amounts of treated it.
I know that, fairly recently, there have actually been supposedly large-scale implementation that are made available to commercial customers, and those details of that.
Get back to you. But, as far as the evaluation, you're just looking at, let's say, total destruction on a mass or molar basis, and right now, it isn't anywhere near as fast.
And nowhere near as fast.
You're talking about words like metric tons.
We're not stretch.
We could be notes or we could simply useless in terms the amount that we are.
Follow up that curve, so, as for its text.
Remember that it is important.
Look at, of course, Total organic or a picture in these images.
Part of it is still eating the large challenge, right?
Whether it's treatment systems, whether it's all of these using organic.
And you can look at the fluoride compensation. So, not. Most of infrastructure. For you.
But, in fact, that's the question. With all your knowledge on the topic.
That's what we do, is to do. It on a large, we do it on a small scale to measure that.
So, the total organic point, but also. So, what it does, what we actually asked me, get to 40. But we can also separate measure directly in your sample. Like? Can I ask a question about that? So, what is the reporting limit for that as it still? Is it still 500 parts per trillion?
I heard it was like one was it keeps going down right for your total organic flooring method.
So, for the lowest detection levels that we have, for these 40 members, right now is for, that 621 method that had sort of organic boring. And that is two parts.
Oh, OK. It's two PPB. I had heard that. It was 500 parts per trillion.
So, what's, what's going on right now is that we are working on ways to optimize that procedure?
In fact, we're already starting to do one of them So it is possible that we're going to get below that part for the good work. But the method is written right now. The detection limit is two parts.
Right. And I think that that's kind of like, where the where someone was asking about evaluating them is that, you know, it's wonderful regnery, why we want that magic bullet, where we can see every carbon fluorine bond. Right, But were to close that mass balance loop.
We're just not completely there yet, So I think once that's done, it's going to be much easier to evaluate all of these destructive, novel, destructive technologies.
I do think that, given the methods that we have right now for total chlorine free, I think there's still more thoughtful, low level of security, that that's really what's out there. But I'll tell you, just because I already numbers every day, there's a lot more of it.
With associated methods. So, we're talking about levels of what I can.
Tell you, they are unfortunate.
one question, and this is speaking as an audience member, because we have to all some questions, and just about time, so I didn't know a question or a data question.
You mentioned that your organization is assessing a lot of process, or potential properties, facilities.
Then, you also mentioned that, now, you have seen Incidences. Where are you adding ...?
I'm curious, how many?
How many sides you came across, like me now.
We just started at screening for it, and we have not passed on anything yet.
I will tell you, and we literally just hired an individual on Monday, do come from a consulting background and represented, uh, like seashores, like, like Quick Trip.
And she has alluded to, shouldn't say a number, it was just all in the French State, probably less than five, kinda crosses sites in due diligence.
They're being hits.
We haven't yet.
I suspect that once we moved fully, answer the 2021 standard, really started with, we're going to find it.
But so far, we haven't found anything yet.
I have a question for you. To ask questions.
So, I'm curious, when you look at European, an Australian regulatory programs, their standards are higher than what EPA the road is going down and just work the only sign out, or Julie.
Can you explain what's going on?
OK, yeah, central viewing data.
I think that, in a sense, some of the agency, The Bureau, lot stricter, but, in a sense, they're more pragmatic.
And I think EPA is doing more serve them in their parts.
Archer, are a number of reason, being one.
So, I think that's the difference.
It's just a level off risk, acceptance by the sages.
So, they don't, they don't look for, there's your local changes in response to vaccines or, they don't necessarily think that a slight changes in metabolic response in rats or mice is enough, but then, I think they're looking for a little more tangible, like I was talking about, Kagan Based Evidence.
That's, That's: And then there's no prospect of, anytime you get sued all the town hall, Don't challenge, it was here because they don't want the lawsuit's, right?
I didn't have a lot of interesting content, I'm gonna combine multiple speakers thoughts to You on, and I really do look, that happens.
We looked at Mass, centralization.
And that's closest, maybe lowering the amount of sources, then we have those things.
And, that's a question to me when, you know, you say, I know you need to concentrate ethos at various sites.
It's the concentrate on any value.
Someone could concentrate, but will re-use it in that low transaction.
Is there a commercial viability to that concept?
I don't know.
I really don't know.
I mean, you would have to deserve it and then in the Desorption process, you would I don't know.
I mean, it's possibly true.
I don't know add to me.
When I think about concentrated PFS, I think about the liability, that *** concentrate can have effects. Not treated.
Think of that. like if you have very concentrated material and it impacts a water supply. It doesn't take a lot, so I don't know.
It's interesting to insert interesting concept.
But, Andrew, on the spots sounds just for relative people who maybe aren't leaves on some of the toxicology, can you compare?
And contrast toxicology What we're talking about, us, and I'm not sure about the HIA. But, let's move on to our Singeing side.
Parents, trust, people, switch things over more busy, or.
Just to give some perspective, frequently people, thank you for that. We are familiar with that, Jane.
Bombay installments cut by offsetting PCBs.
So, Impass, if you compare apples to apples, are ultimately left off, then those.
So, benzene, we talked about. Non citizen EPA elevated people should be part of life.
Now, it's still, quite a ways away, the battle on this agenda.
And then all the non top perspective, I'll give you one example.
Have an aquatic ecosystem.
There's almost zero type of system, which is go work.
You think that such compound with hartsburg, chosen level concerns, aquatic systems, which are biological systems, are generally unresponsive.
Any scientists you talk to ask them about because we have those ethylene test document. Yeah. We have it now.
And so on, Austrian I don't think they will do that at all.
So much a problem from the practical perspective.
There are not asks same as they seem to be portrayed in general.
So, in the interest of raising my salary by six years, yeah, why it's been seen as it were.
Yeah, talk about it, because it's not A compound names.
It's not off interests too, EPA, acts, and groups who are pushing for.
So, it's a political, somewhat, it's a political issue.
The bold ...
bio-accumulative, Can you speak up? Yes, I'm sorry.
Population long chains to go in the driving, the target levels down my lifetime. Water consumption levels, so it's, it's lifetime information. That helps to that, because it's part of driving those levels to lower than what we see in other ways to acute.
Not sure, inspire, stand.
Well, colonial exposure, south-east for biological systems.
In human health yes, you don't talk about short-term, long-term.
But, in terms of its toxicological endpoints, they typically reflect probably longer term exposures as the point of departure can calculate against the house.
And by accumulation potential is not considered per se.
All right, it may be included in the uncertainty factors, indirectly bad.
I don't think that accumulation, it's driving those numbers down.
That's a question?
That's the toxicity part of the barge.
Lunch is that it Does that answer your question?
Sorry, my son isn't working.
OK, we'll put you guys in the backseat of the car later. I have a question for reach it. So you mentioned about called ... of the US and abroad.
Yes, so, I was just thinking instead of trying to contain FIFA, fortunately, it's still wanna be in the environment in some way.
Why can't we just find it, because it's been around for a long time, why is it stay here?
We know all the side effects that It's posing to the environment and people, animals, and all those things like us. We just Oh, yeah, And that is one of the three of them component options that we could go towards.
I would argue that the only reason why we haven't moved towards that is because chemistry is very useful if there's a reason that's around, yeah.
That, too, if you want to be a little bit worse.
Products, also, I got the Paramount Capsule States Meetings, Which is the as quality juice.
Guest speakers for a couple years ago, or bits, they're tired of this, is that there's a deal to deliver something better.
We're going to choose mission over avail until we're sure people were getting their lives and they were like, oh, mission comes before environment, Jerry Lee.
And it's a reasonable.
But even in this situation, where we did eventually find an alternative, which has been working on that for my handler, over five more decades, um, you still have the issue of feedback. So you're already in the environment, right?
And if we reach a point where we decided, like, there is an environment risk at the level of exposure that currently at you still need to remediate that, obviously, you can't have waste streams running around doing it, would be good to have more.
I guess that witnesses to be produced on water? Unless you can say, OK, Yeah, but, you know, not releasing it back to the greater environment.
Yep, not another band. It's very difficult, substance, typically done on the desktop.
And it's not a matter of bad, It's certainly uses, and it's a long process.
So even if we wanted to ban all in any, It will be our law, what type of process? And then, to the office.
Why is that?
Those are Because that we know, yeah. No. That's not.
So, it will be more difficult than.
I'd like to suggest that these are not natural compounds, these compounds carbon bond.
I know we've spoken about before. That it really takes one of temperature pressure on those, so they're not just their sponsor industries that are producing.
and using that there should be some responsibility for that, enables you, whether it's knowledge or a process for their sake, let us all know what is coming out in its place, into the air today.
I think it would be really interesting if somebody showed what our products would actually look like if we took this floral chemistry away right? Now, the reason why it's so prevalent is because it does so many amazing things. Like this is why our clothes are waterproof, this is wire or furniture isn't stained, you know, it's the reason why things are microbial resistance. Like, you know, countertops are treated so that, I mean, I think would be very interesting. If somebody could show that and say, OK, if we wanted to do this, this is what the environment, and this is what our products would look like, because it would take a huge commitment.
Try individuals to allow that to happen.
Not saying that we shouldn't, I'm just saying that. You know, saying, Well, why don't we, it's just so prevalent in, in everything, in our, in the last 50 or 60 years.
I'd just like to add to that, yes, there are the corner like increases More.
And so, I think that it is important that if we know the key facet is in these products that are being put into our on to our carpets and our furniture to keep it, does that. If we know that there's then we, as a consumer, we are able to fix those choice. That's great for ourselves, right? Yeah, I agree with that completely.
A lot of studies. We. Understand your cellular and molecular level, how it's actually affected by such a way to start.
Cause applying this paper wasn't structured the same way. So you ask the question, What is the amount of action? Yeah.
So looking at it, why not be?
Games is the oxidative stress, essentially, plus molecules.
You guys do with charges on your model.
I didn't notice. That charge, they all. Tend to find something to sell.
And this could be DNA damage, it could be other molecules.
Essentially it has reactivity to it.
There is a neutral tail there Harvard, going J pal that was long and short, and there is a gap which are sulfur oxygen.
And then that, and that's the acid, and that will tend to do something.
There's, there's data coming out the amount of activity on that end event on that type of pattern, it represents.
But that seems to be the most common they receive.
Now the fact is that we have great systems, not long.
I'm the United States, thousand times a minute.
Well. We fixed. that.
Are saying that.
That's the part, oh.
Any other question?
Third adding started off and the precursors to surplus designation.
When do we anticipate that would actually be finalized? Litigation? obviously, there's no copyright date on that yet, but a couple years.
I would guess, at least a couple years, the time that it takes just for the litigation to work through before we even see it.
The designation that I just, I would be super surprised.
They may try and blow something out there.
You're in early spring, much like, No, we're not talking about other things.
Like, what does that? That's what happened was out there. And then it just gets all tied up the tangled in forts. And I would just be shocked that we see.
Oh, that makes the price.
Show and take, students report.
Well, some pieces, as well.
In regards to your thinking baseline assessment.
Why consideration is given to air quality is that, you mentioned land, water, and all this, but there's never, one time it should error, so, this, I've been really obsessed with ..., modern anyone about it. But we know that it travels so readily in air, and so what my abilities are having to care for that niche? Right?
In 20 13 that, that ASTM revision actually introduced, really for the first time, something related to air.
It was untrue.
So, think of subsurface contamination or if it's volatile and it could come into a indoor space and then the exposure of an ally is hailing that confidence.
Um, with P boss, I have no idea if that's exposure mechanism, Mitch. And that's it.
That's actually on the fate and transport, I think there's indication that denied the exposure that you saw.
I am, yes, This is sound coming through better now.
Yeah, OK, good, thank, thank goodness. Brand microphone connected, here? Um, yeah, it's, it's going It's a growing concern Definitely. I think there's still such a limited amount of data in terms of whether it's a risk, in terms of indoor air, exposure this fraction of VP faster volatile. It's, it's pretty small that usually significant mass fraction of these releases, but, it's there and it's, it's present.
So, the indoor air, definitely a growing concern, but not clear.
At this point how big of an issue, it's ultimately going to be what has been a big issue of concern with P, fast and air is emission instead of lead lead to Tabak Round.
Contamination in areas where high concentrations have been used as part of industrial processes are or over incineration has been done wrongly and and lead to local contamination into into soil. So it's less of an acute exposure.
In those circumstances as a source of of background, PFAS contamination in an area where it would otherwise not be expected, Then at the top of that, specifically terrain block, a magnet for intercepting Airborne Paypass molecules.
I'm bringing them down, service Yes.
Yes, and then, of course, there's all sorts of different scales, I mean, P facets, small enough levels, but enough to produce that. There's global scale transport to, and how big of an issue that's going to become in terms of regulations is, is much more uncertain. I think it's clear that the smaller scale, local, high concentration emissions that are that, have gotten the biggest attention up to this point. The EPA has a method for analyzing for ...
for collecting samples O, T M 45, which collects data for select PFAS compounds, volatile PFS. And I think, expect more action in that area as well, in the not too distant future.
one more thing, because you mentioned the goal of transfer pathways, mm European community, and maybe as failure and states and Canada are aware, and maybe controlling emissions, but I think parts of the country, my knowledge, there are still lab as well as those produced a manufacturing cost issues.
So that signature, ultimately will have a footprint around the globe.
Which is, there is a discussion.
This concept of like a global backdrop. That's patient.
Yeah. There's been a good amount of published studies where they've done background analysis in remote areas and detecting for low enough concentration. It's, it's there wherever they look for it. I don't see that, I haven't seen any discussion towards actually turning that into a kind of an established background level.
However, I think it's pretty variable still regionally, in terms of what those levels might be regionally on a global scale, as well as regional yana now, within the United States, kind of a scale.
Correct me if I'm wrong, but they're still producing PF away and PFOS, and China my correct.
Yes, I think that would be really difficult. Yes.
Well, yes, when you're looking at site selection, keywords that farmland and pesticides, then on your radar yet it does, so I'll give an example.
So, the way click through rates, we go on e-bay a market, and so a market that we've developed this Phoenix area Phoenix there has been historical orchards and so organic are cynical, or a problem that we've added them to our suite of analyzes that.
When we, when we do at phase one, we're going to do a two out there, and we're gonna always sample, or organic, our Senate bills associated both long term SSI. So, yes, it certainly is.
Um, but we don't, we do. That.
Just based on you know, we have local knowledge, You know, we rely on consultants that live in markets that really understand the just what the background is, and we sample for those specifically.
I mean, that's another, um, area for me as well, right.
So related to agriculture and yeah.
Yeah, I would agree with that.
It wasn't the containers. That was the nature of the containers.
Bounds and those leaf, as leached into.
EPA has investigated that, let's look at search, encourage satisfaction factors The system, not in itself.
It does go a little bit there, OK.
Of course, you want to keep exposure to pesticides people back to this effect but then, of course, some of the target it enters the image of that.
It's a ordinated compounds, and you could add that. We don't know what to do, we get? But we're not gonna allow.
And then, on top of that, it's generally less correlated, but there for a test or a pharmaceutical pass that style been very targeted.
I don't know if there are 42 directly directly, as I didn't know they weren't yet considered.
They don't get paid, So it depends on. 420 kids that they do not have enough information on each. Of those are for them to be categorized as, sometimes they also have other.
It's one of those things where we just still should be, or to turn on all of our radar.
She's follow-up question on that, would it be, would it be detected in your total organic fluorine analysis?
Yes, it would, OK, Hmm.
OK, I think that's comes to the end of today. I want to thank all our speakers.
I, many thanks.
Amy, Amy, you you've done great co-ordinating and keeping us all on track. Thank you.
Thank you, everybody for being able to see you Watch it, OK.