PFAS Practice Langan’s PFAS expertise brings value to your projects with practical and client-focused solutions. Our experts are your environmental advocates. Langan’s Per-and Polyfluoroalkyl Substances (PFAS) Practice Langan’s PFAS practice focuses on the investigation, remediation, and management of contaminants of emerging concern with a particular emphasis on per- and polyfluoroalkyl substances (PFAS). We are engaged in the complex and rapidly evolving technical and regulatory aspects of PFAS investigation and remediation and have extensive practical experience that provides value to our clients. Our core team of PFAS professionals located throughout the United States has diverse expertise in PFAS sampling and analysis, chemistry, history of use, site characterization, fate and transport, treatability studies, treatment and remediation, regulations and regulatory policy, risk assessment and management, compliance, data management and visualization, and other related specialties. Our portfolio of PFAS projects includes facilities in the following categories: fluorochemical manufacturing, aviation, petroleum refining, petrochemical manufacturing, semiconductor research and development, electroplating, military, fire training and response involving aqueous film-forming foam (AFFF), wastewater treatment, public water supply, and others. PFAS Regulations Information summarized herein was compiled based on multiple state and federal regulatory releases and the August 2022 PFAS Water and Soil Values Table (August 2022) published by Interstate Technology and Regulatory Council Per- and Polyfluoroalkyl Substacnes Technical and Regulatory Guidance. Values presented herein should not be considered comprehensive. Many states have various exposure scenarios and pathways that are not represented herein. The information contained in this map will be updated periodically, but may not represent the most current standards or the full nuance of a given State’s regulatory approach to PFAS. User’s are encouraged to contact a Langan representative for more information. Our Services Due Diligence Evolving PFAS regulations at the state and federal levels have added complexity to real estate and business transaction risk assessments. Langan draws from extensive PFAS knowledge and experience to advise clients on transactional due diligence and develop assessment strategies aligned with their business objectives. Our environmental professionals stay abreast of changes in best practices, including compliance with the American Society for Testing and Materials E1527-21 Standard Practice for Phase I Environmental Site Assessments and the Environmental Protection Agency’s All Appropriate Inquiry rule. Langan also routinely performs non-transactional PFAS due diligence, typically for clients required by regulation, to assess their potential for PFAS impacts or for facilities that seek to proactively identify and manage potential risks associated with historical and/or current PFAS use. Regulatory Compliance Langan is actively involved in state and federal regulatory stakeholder processes involving PFAS and emerging contaminants. Many of our PFAS experts participate in stakeholder groups and provide input on technical guidance. We assist our clients with regulatory compliance related to PFAS including compliance monitoring and testing, discharge permitting, stormwater and spill planning, and compliance with reporting requirements under various federal and state statutes such as the Emergency Planning and Community Right to Know Act (EPCRA). Sampling and Site Characterization Langan has sampled various environmental media for PFAS at numerous project sites throughout the United States. In doing so, we have gained valuable perspectives that we leverage to assist clients in meeting their regulatory requirements and business objectives. We routinely advise clients as they decide whether and when to initiate sampling. Sampling plans and programs are often phased. Some of the factors to consider when preparing a PFAS sampling plan include: Current and anticipated regulatory requirements and standards PFAS to be targeted Properties and anticipated concentration and distribution of the targeted PFAS Laboratory capabilities and analytical methods Background sources and concentrations Minimizing the potential for cross-contamination Potential outcomes and approach for data interpretation. Langan brings perspectives and knowledge to our clients from our direct involvement developing the Sampling and Analysis sections of the Interstate Technology and Regulatory Council’s (ITRC) PFAS Technical and Regulatory Guidance Document, and from our relationships with laboratories and analytical experts nationwide. Fate and Transport Understanding PFAS chemical fate and transport processes in the environment is vital to assess potential risks from a release, determining where sources and receptors may be located, and evaluating potential remedial alternatives. We have extensive experience assessing chemical fate and transport with appropriate investigative, analytical, and modeling tools. We recognize that PFAS have unique and varying properties that influence their behavior in the environment, often resulting in atypical transport pathways and distribution patterns. Analysis Risk Assessment As PFAS toxicological studies advance and new standards are published at the state and federal levels, Langan critically reviews the basis for these standards and interprets the implications for our clients’ regulatory obligations and liabilities. In addition to staying abreast of PFAS-related regulatory developments, Langan guides clients in evaluating and managing PFAS-related business and environmental risks in anticipation of evolving science and state and federal regulations. Langan has developed innovative risk-based approaches for PFAS, including site-specific PFAS screening levels for groundwater and soil in certain instances where guidance for risk management and remedial action decisions was not provided. and Management Treatability Studies Langan performs most laboratory-scale treatability studies “in-house” through our unique, collaborative partnership with the New Jersey Institute of Technology (NJIT) Center for Natural Resources. Langan has direct access to NJIT’s environmental laboratories to evaluate a range of potential remedial technologies to support remedy selection. Langan’s Treatability Facility at NJIT provides critically valuable information for selecting and designing applicable, practical, and cost-effective remedial technologies, and helps to optimize remedial operations using in-house confirmation monitoring. In addition, we have unique access to NJIT’s academic researchers, who are pioneering innovative approaches to analyzing and remediating PFAS. Treatment, Remediation, and Waste Management Designing and implementing cost-effective PFAS remediation strategies is challenging because of the unique and varied physiochemical properties of PFAS, their recalcitrance, low regulatory thresholds, and the evolving scientific and regulatory landscape. Langan is directly involved in leading-edge R&D initiatives with industry partners, and helps promote knowledge sharing and technical advancements through our contributions to the PFAS Experts Symposium and ITRC training and guidance. Langan routinely guides clients through evaluating and selecting PFAS remedial alternatives, performs treatability testing, leads or performs the design phase, and manages the remedy implementation. Factors to consider in evaluating PFAS treatment include: Type of media to be treated Types and concentrations of PFAS, including polyfluorinated precursors if present Presence of other contaminants Remediation objectives Previous or concurrent remediation efforts Regulatory requirements Intended property use Subsurface conditions Site constraints Owner’s risk tolerance Requirements of the receiving facility (for off-site disposal options) Forensics and Expert Support Langan often supports attorneys and their clients by providing a range of PFAS expert services in connection with litigation and insurance claims. These services include: Strategy development Technical discovery support FOIA records requests Document management Database development and management Data analysis and forensic support services 2D and 3D modeling and visualization Cost/damages estimation and allocation Technical support for settlement negotiations Preparation of expert reports Coordination with other experts Testimony Regulatory Compliance Sampling and Site Characterization Fate and Transport Analysis Due Diligence We have experience applying our knowledge of PFAS history of use and chemistry in combination with various analytical tools to forensically distinguish PFAS from comingled sources and plumes. These tools include compound ratio analysis, isomer analysis, multivariate statistics, product analysis, and use of expanded and/or non-target analyte lists. Our technical experts offer exceptional value and critical technical evidence to support legal cases.