PFAS Due Diligence Part 1: ESA Scoping Strategies
December 14, 2022 @ 1:30 pm - 2:00 pm EST
PFAS is included in the E 1527-21 Phase I ESA standard as a non-scope emerging contaminant and EPA has published a proposed rule to list the PFAS family of chemicals as hazardous substances under CERCLA. Based on feedback from our recent benchmark survey, the industry is split on how and when to integrate PFAS into the scope of ESAs.
The panelists will highlight crucial technical and legal issues, including:
- If PFAS are “everywhere,” should we always include it?
- Should we limit PFAS consideration to only known contaminated sites?
- What do we do with the “potential impact” sites?
- How do current regulations and future enforcement impact scoping?
- What are the most important scoping factors to discuss with clients?
- What if a client doesn’t want to include PFAS in the scope?