The recent pause in the industry due to COVID-19 allowed The Blackledge Group time to reflect on our values, refocus on our commitments, and further define our vision for the future. We also completed several complex projects designed to provide answers to our clients to reduce their environmental liabilities while maintaining regulatory compliance. Field work was completed prior to the pause, which provided an opportunity for our knowledge professionals to dig even deeper than normal into data validation and interpretation of the collected field data. One of our primary commitments as a firm is to focus on assisting local, state, and federal clients understand and address “Contaminants of Emerging Concern, or CECs” that may impact their water supply systems. Recently, investigations at the state and federal environmental regulatory levels have focused almost exclusively on Per-and Polyfluoroalkyl Substances (PFAS) at sites contaminated with Aqueous Film Forming Foam. Many other CECs have been identified by the U.S. Environmental Protection Agency (EPA) and are in varying stages of scientific investigation.
The term CEC includes a variety of chemicals that have been detected in public and private water supplies, are unregulated in the United States at the Federal level and have real or perceived potential adverse environmental and human health effects. Researchers continue to identify and document that many chemical and microbial constituents that have not historically been considered a contaminant are present in the environment on a global scale. According to the United State Geological Survey (USGS), these CECs are commonly derived from municipal, agricultural, and industrial wastewater sources and pathways. These newly recognized contaminants represent a shift in traditional thinking as many are produced industrially yet are dispersed widely thorough the environment from domestic, commercial, and industrial uses.
The major goal on the science side of the equation of Emerging Contaminant investigations is to evaluate their potential threat to environmental and human health. To accomplish this goal, the USGS and other similar research agencies have developed complex research activities including developing analytical methods to measure chemicals and microorganisms or their genes in a variety of matrices (e.g. water, sediment, waste) down to trace levels, determine the environmental occurrence of these potential contaminants, characterize the myriad of sources and source pathways that determine contaminant release to the environment, define and quantify processes that determine their transport and fate through the environment, and identify potential ecologic effects from exposure to these chemicals or microorganisms.
As more of these emerging contaminants gain steam towards regulation on the federal level, the primary targets for causation focus on determining what portion of the contamination falls under their regulatory umbrella. To determine this, additional research is required outside the purview of “hard science” and the focus turns to resolving uncertainty.
Which brings us to a highly specialized research area involving identifying Potentially Responsible Parties at large complex contaminated sites. An example of a recent study performed by our scientists involved identifying potential PRPs along a river system impacted by PFAS. One of the many tools available in The Blackledge Group’s toolbox is providing an in-depth search for PRPs at these complex CEC sites. The Blackledge Group has performed numerous PRP searches for governmental and industrial clients at a wide variety of sites. Our focus is on compiling information to assist in identifying responsible parties. Our “toolbox” includes developing site ownership and site occupation history, searching public and private records, reviewing site-specific data, performing interviews, reviewing aerial photographs, assisting with cost allocation formula development and cost evaluations, and performing a compilation of records pertinent to the investigation.
The Blackledge Group’s experienced and knowledgeable staff members are available to assist with any portion of reviews needed on your RCRA, CERCLA, and CEC related projects.
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