Jeffrey D. Marshall, PE, and Michael J. Miller, CHMM, discuss environmental due diligence and how the proposed CERCLA rule could impact the number of recognized environmental conditions. The authors discuss the type of properties and former uses that are more likely to see an increase in PFAS-related issues during an environmental assessment.
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Impacts of CERCLA PFAS Rule on Due Diligence
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[ii] The HS designation of the salts and structural isomers of PFOA and PFOS may be considered somewhat non-specific, leading to confusion, particularly among non-chemists. As such, we hope that the final HS rule will provide more clarity and specificity – e.g., a list of specific PFOA and PFOS salts and isomers, including CAS numbers.
[iii] Presumptive Contamination: A New Approach to PFAS Contamination Based on Likely Sources (Salvatore, D., K. Mok, K. Garret, G. P:oudrier, P. Brown, L. Birnbaum, G.Foldenman, M. Miller, S. Patton, M Poehlein, J. Varshavsy) In Environmental Science and Technology Letters, 2022
[v] https://www.epa.gov/pfas/pfas-strategic-roadmap-epas-commitments-action-2021-2024
Additional Information: Environmental Due Diligence
